Subject: File No. S7-14-08
From: dav id a sunderland, clu

July 17, 2008

the fixed index annuity product is the best product for the majortiy of retirees and pre-retirees to have in their portfolio since it GUARANTEES their principal and any gains
will be their when they need them. this GUARANTEE is very
important in todays volatile economic climate and having the guarantee will be even more appreciated in the years to come. Having the assets in the FIA guaranteed by the assets of the insurance company provide protection afforded
no where else with a product that will also allow some index gains to be credited as they occur.With mutual funds and variable annuities having a place in some portfolios for those who are not risk adverse by adding FIA'S into the mix also the client has the best of all worlds. The fixed annuity business is regulated by the insurance commissioners of America who have done an outstanding job over the decades and no further regulation from more governmental or quasi-governmental agencies is needed. FINRA's desire to include the FIA business under their umbrella is mostly self-serving to insure they can make a economic gain off sales of anything that a person purchases for retirement. After 40 years in our profession I can see what FINRA is trying to do and it is absolutly not needed to have them regulate something that is already controlled by professionals in every state through our insurance commissioners which are highly competent in this arena. I am firmly against any regulation of FIA's that would try to make them into something they are not(a security).