Subject: File No. S7-14-08
From: James T Johnson

August 4, 2008

Dear Sirs -

The SEC's proposed rule is due to it's desire to charge or 'fee' a already regulated, fixed insurance product.

Yes, there has been small amount of unsuitable sales - But has anyone every looked at the amount of money lost in mutual funds or variable annuities over the last few years?

To my knowledge, it's very difficult to regulate good judgement and common sense.

At least with fixed, indexed annuities - consumers have a safe choice to mutual funds or variable annuities. Not all contracts tie up the clients money for years and years.