Subject: File No. S7-14-08
From: Alan Halka, CFP

July 30, 2008

I am a CFP and have worked in the industry for 17 years. I am uncomfortable with the SEC decision to look at Fixed Index Annuities as a security. It is a direct slap in the face to the STATE controlled Insurance Commissions. I would imagine if the SEC changes its position on these fixed annuities after 9 years... it will only result in billions of dollars spent in lawsuits where the consumer loses, the agents lose, businesses will lose, and the lawyers will win.