Subject: File No. S7-14-08
From: Michael A. Halterlein, Sr.

August 4, 2008

The SEC should not be the regulatory body for insurance products. FIAs' are insurance products based on the fact that the purchaser of an FIA, just like any other annuity, does not bear any market risk and is guaranteed return of principle and a minimum rate of return that can be earned with the potential to earn higher. The purchaser has no investment risk. All investment risk is shouldered by the issuing insurance company.

The insurance industry is very ably regulated by the state insurance departments and the NAIC. While there is misrepresentation by some individuals in all sales industries, the insurance industry, NAIC and insurance departments police agent practices very well. Agents are required to complete ethics training. They are also required to complete suitability statements signed by their clients when they sell an annuity.

There is absolutely no reason FIAs' should fall under the jurisdiction of the SEC since there is no relation to equities. There is no risk of financial loss to the purchaser of an FIA such as there is with a mutual fund or stocks or variable annuities.