Subject: File No. S7-14-08
From: Michael A Menck
Affiliation: CEO

November 17, 2008

Security licensed marketers, by their questionable actions and past strategies, have surely magnified the current mess orbiting the financial services industry. To bestow total control over the sale of all savings vehicles to this questionable group would compromise the future needs of those who would benefit from the purchase of an annuity plan when that plan is needed.

Greed seems to be a common bond among security licensed financial houses and their agents. In these tumultuous times, one could easily believe that a brokerage house and/or it's agents might put their client's needs second to their own in the sale of security based investments and savings plans. To reduce the competitive field by restricting all sales of annuities, outside of this securities licensed group, would be a recipe for further abuse, loss and damage to innocent people. Annuity sales by insurance agents provide a competitive balance.

After twenty-eight years in the insurance business, I have found that career insurance agents place their clients in annuity plans as part of a portfolio to meet and compliment individual and family financial needs. Insurance agents strive to establish, provide and secure a balance of financial solutions to meet a multiple of insurance and savings needs. To restrict insurance agents from what has been a time tested practice of selling annuities will simply remove competition and reduce the scrutiny of those who might solicit for their own need for greed.

Let the insurance agent continue to do what needs to be done promote and protect their clients futures.