November 14, 2008

Subject: File No. S7-14-08

Equity Annuities should ABSOLUTELY require securities license.

Most clients are misled inadvertently because the agent does not understand how they work.

Agents describe the product as simple and straight forward, but the product is quite complex.

Since the underlying investments within the equity annuity are securities products, I don’t understand why placing them in a wrapper make them not a security.

Clients should be protected by requiring distributors of equity annuity products to fully understand the internal complexities within the product and that can be assured by requiring securities license.

Thank you for this opportunity to comment.

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Tracy Miller, CFP® , CLU, ChFC
TMiller Financial
Retirement and Estate Planning