Subject: File No. S7-14-08
From: Helen Modly, CFP/ChFC
Affiliation: Focus Wealth Management, Ltd

November 13, 2008

Dear SEC:

These products are being inappropriately sold as an equity vechicle with no "downside" risk. The commissions involved, the underlying fees and the surrender periods are predatory at best. The calculation methodology is strongly tilted toward the manufacturer and not the consumer. If these products really provided the benefits the salesmen promise, there wouldn't be such a groundswell of complaints against them. Please be aggressive in regulating these products and the people who sell them.

Helen Modly, CFP/ChFC
Executive Vice President
Focus Wealth Management, Ltd