Subject: File No. S7-14-08
From: Earl J Spear

July 24, 2008

COMMENTS ATTACHED: It is obvious that fia's have been outside the definitions of SEC control for a long time. This product does not fall within their control rules and now is being proposed to take a key product away from Life Insurance agents. It appears this total effort is just to deny agents a stable insurance product for their clients. Past history establishes a prescedence in this case and I appeal to the courts to recognize that basic fact. Thank you Earl Spear