Subject: File No. S7-14-08
From: Wayne Guthrie

August 8, 2008

It is apparent that in a product that is traditionally used to provide earnings potential without the downside risk of market fluctuation, further regulation is not necessary. Safeguards are already in place in the heavily regulated insurance industry.

Attempting to classify FIA's as a security product will do nothing to protect the consumer and will actually impact the cost of doing business which will ultimately lead to lower earnings for the consumers you propose to protect.

I respectfully request that you abandon this notion and focus more of your attention on products that actually are securities where from time to time unscrupulous individuals take advantage of consumers. Your reasons for taking this action seem to be influenced by a powerful lobby who are looking to raise their own revenues at the expense of the consumer and those reasons are not supported by the facts.