November 17, 2008

Subject: File No. S7-14-08

Please consider the following:

The proposal is not supported by any empirical evidence that supports the Commission's claim that widespread abuses in selling the product exist.

I have met with hundreds of customers over the years and the abuses that I see are related to activities in the financial markets committed by stock brokers that put themselves out as financial advisors.

The Commission's action would restrict public access to an increasingly popular product. I think FINRA wants to create fees that would stay in their pocket vs. letting the Insurance business take care of itself.

The appeal of indexed annuities is that they are not securities and not subject to risk of loss from market activity. My clients did not lose one penny this past year.

Fixed indexed annuities are currently subject to comprehensive state insurance regulation that I uphold and maintain continuing education that is more effecting than any Regulatory or Firm Element that I have ever taken for FINRA.

Please stay out of my Insurance business.

BRAD D. SILVER
PRESIDENT
PRINCETON TAX ADVISORY GROUP, INC.