November 13, 2008

Subject: FPA member against File No. S7-14-08

I am a member of the FPA and I’m against the rule. I am a Certified Financial Planner Practitioner for over 10 years.

There have been abuses with all investment products over time. But having registered reps needing to place their equity index annuities through a broker-dealer and having non-reps use different criteria is not the answer.

-Mitchell Kraus