Subject: File No. S7-14-08
From: Lawrence P Leisenring

November 17, 2008

I have been both a life and health insurance agent and registered representative for over 25 years and strongly feel that Fixed Index Annuities are non-securities, since there is no risk of loss due to market conditions, there is full disclosure regarding guaranteed returns and since any surrender charges are fully disclosed.

I am a big believer in disclosure and it upsets me when an insurance agent or a registered representative does not fairly and fully disclose the risks associated with a fixed insurance product or a security, but I do not see how making FIA's a security will change misrepresentations or a consumer's misunderstanding.

FIAs are definitely not for everyone, but they so not have the risk associated with securities and do have the guarantees associated with an insurance product, hence it seems to be misguided to take them out of the realm of being a fixed insurance contract and placing them in the catagory of a of being a security.