Subject: File No. S7-14-08
From: RANDY FRANKENBERRY
Affiliation: CEO, FRANKENBERRY ASSOCIATES INC.

July 8, 2008

The SEC is overreaching thier regulatory authority. How can you declare an annuity which offers a guaranteed rate of return regardless of how the market performs be regulated the same as investments that involve risk. There are others ways to police insurance agents who misrepresent products than this proposal. Each state has a dept. of insurance whose responsibility it is to oversee this. Getting the SEC involved would be a waste of federal taxes and will cause many to pay for the mistakes of a few.