Subject: File No. S7-14-08
From: Brenton L. Fewox
Affiliation: The Oxford Group, LLC

July 30, 2008

After having been in the business of financial advising for 17 years, I find it hard to believe that we are at this point. It has
always been my understanding that those products that offer a guarantee have never been considered to be a security product. There are a lot of reasons to have oversight on securities because of their nature of possible loss. It makes no sense to me to increase oversight and complicate a product that is simple and guaranteed in it's nature.