Subject: File No. S7-14-08
From: Ricky M Metcalfe , III

July 23, 2008

All Fixed-Indexed Annuities should continue to be overseen by FINRA, and not the SEC as they are savings vehicles and not investment vehicles. The principle contributed to an FIA is not directly impacted by "market" fluctuation. Furthermore, it's unfortunate that the majority of individuals that have a negative opinion of FIAs and their performances do not posses a proper understanding of these products and their purposes. Personally, throughout my entire career in the financial services industry, I've never witnessed a first-hand complaint from a consumer regarding the positioning or performance of these products. If SEC151a is ultimately enforced, many organizations and individuals will be negatively impacted in a number of circumstances. Jobs will be lost, organizations will become obsolete, industry professional will be required to spend more time and money for credentials, etc... I do not deny the occasional abuse of these products. However, the positive impact that FIAs have on individuals and their legacies completely outweigh and overshadow the occasional ramifications of those who abuse them.