Subject: File No. S7-14-08
From: Paul A Dyer
Affiliation: LUTCF, Licenced Insurance Consultant,6 ,62,63,65

July 18, 2008

Ive been in Insurance Business for 28 years and have 1000+ clients. Although I'm sure that are miss uses or inappropriate uses going on with FIAs making them a security is not the answer. In fact, it will make the underlying use more of a problem in several ways. Advisors who are truly talented CFP ,RIA or other securities licenced usually have an account minimum that would then exclude many "Middle America" buyers from having access to a tool that serves them well in the correct proportion.You might stop someone from leaving the stock market earning 10% over time, from going FIA and thinking they still would earn 10 because of a incorrect explantion from an agent.The problem is that you are also going to stop that CD saver who is currently earning 3 less than the CPI from finding a vechicle that would help them yield perhaps 6% from doing that as well. Those are the persons that would never go to..talk to or even consider a securities dealer. They also are the people that will end up on welfare in their older years after two decades of not beating the CPI or CPIE. The wealthy client that earns less than they would have will see and react if they don't get what they expect. They also are less likely to end up on welfare. Pass a law that makes putting more than 50% of anyones assets in an insurance product and you might start forcing people into behavior that would be good for them and the country. Making a fixed account into a security is not. Wrong treatment for a current problem. Try again.