Subject: File No. S7-14-08
From: James McCreary

August 5, 2008

151a seems to be trying to address a perceived selling problem of FIA's by categorizing them as something they are not (securities). FIA's are a great product helping citizens to protect their retirement savings. Securities are for risk takers. I am concerned that by reguiring agents to become and report to brokers who specialize in selling securities (risky investments) there will be more retirement savings moved into these risky securities, not less. Please do not require agents to report to the brokerage industry which has had a history for "pushing" reps to "push" risky investments. Seniors and people wishing to protect their savings will be better served by the agent whose specializes in safe investments ie., insurance.