November 13, 2008

Subject: File No. S7-14-08

As a member, I have been recommended by the FPA to support the proposed oversight of indexed annuity sales. I disagree with my FPA leadership. In this dire market, countless investors would have been better served by having an indexed annuity rather than a variable annuity. Even with the issues regarding liquidity, I believe the proposed rules are not necessary and possibly self serving for those with a securities license. I have an insurance license and have had securities licenses. The enforcement of proper marketing, disclosures and suitability should fall upon the insurance industry and not more regulations and governance by the SEC.

Very truly yours,

Patrick Carney

Patrick J. Carney, CPA
Alliance Account Executive
FirstCal
First California Mortgage Company