Subject: File No. S7-14-08
From: Terry M Muns

July 29, 2008

It is my deep belief that any adoption by the SEC to regulate FIA's as a security would undermine the freedom of choice for consumers. Moreover, it would greatly affect the pricing structure whereby, causing additional cost ultimately to the consumer as the benefits of FIA would be adversely affected through SEC regulation. Equally important, annuities have been an insurance product from the inception and origins by Ben Franklin. The fact remains that the FIA's is an insurance product designed as a safe money alternative for consumers seeking fixed income products. Quite frankly, with all the debacles of Wall Street currently, the SEC has plenty to do enforcing and monitoring current regulation without adding anything further.

Therefore, it is my fervant desire that the SEC stay out of the insurance product mix and drop the current pending regulation.

Cordially,

Terry M. Muns