Subject: File No. S7-14-08
From: Lawrence T Hakim
Affiliation: Association of Financial Planning

November 18, 2008

As a licensed Insurance agent as well as a licensed financial advisor (SEC FINRA) I do not feel that this pending legilation makes any sense at all. Simply put, a FIA is not a security. I have been selling FIA's since 1995 and have as part of a clients portfolio and have never had a client unaware of exactly what and how a FIA fits as part of their portfolio.
This country spends more time, money and effort barking up trees where nothing exists, rather than fixing the obvious.