Subject: File No. S7-14-08
From: CHARLES A. SMILEY

November 17, 2008

you should not make all sellers of "INDEXED ANNUITIES" HAVE TO HAVE A SECURITIES LICENSE...THAT IS TOTALLY UNFAIR FOR REGULAR INSURANCE AGENTS AND IT GIVES ALL THE OPPORTUNITIES FOR SALES TO THOSE WHO DO....WAY TOO MUCH OPPORTUNITY GIVEN TO THOSE WHO DO...I THOUGHT INVESTMENT ADVISORS MANAGED ASSETS DIDN'T SELL ANNUITIES????...I DON'T MIND THEM SELLING SOME, BUT THEY SHOULDN'T HAVE EXCLUSIVE RIGHTS TO THAT MARKET...AND EVERYONE ELSE CUTOUT..WHERE'S THE COMPETITIVE SPIRIT HERE???/