Subject: File No. S7-14-08
From: Joel I Franklin, CPA
Affiliation: Independent Life Insurance Agent

July 25, 2008

Fixed Equity Annuities (FIA) have none of the clients money at risk, therefor it is hard to understand how the SEC, who regulates securities (investments with risk), can think they have the right to regulate a life insurance product. It appears to me this is just a way to place them in thier securities brokers accounts so they can get their "wrap fees" on them. There appears to be NO JUSTIFICATION to call these life insurance products securities.

I used to have securities licenses but I resigned them in 2001 because I did not want to put any of my clients money at risk, which I can do in Life Insurance Companies.