Subject: File No. S7-14-08
From: Clifford Gaw

August 12, 2008

I am an independent insurance agent, Series 6 and 63 licensed but have dropped my affiliation with a B/D since I have not presented or sold securities for over eight years. I have been reading articles on the SEC 151a proposals and I too am opposed to making FIA a security for the reasons the SEC is stating, "that it will protect the client more and stop unscrupulous agents from selling or misrepresenting FIA's to clients". My business is about 85% Long-Term Care Insurance sales and in meeting with many clients and doing a suitability review, have found that many have been sold indexed and variable annuities by securities licensed brokers and banking institutions that have either seriously mislead or sold unsuitable products to clients. It is the integrity and the knowledge of the product the agent has, that is most important, not a securities license as far as FIA's are concerned. Some security licensed brokers actually sell whichever brings in the most commission, regardless of the clients suitability.

I received my series 6 and 63 license in 1995 and started selling Variable Annuities and Mutual Funds. Just because I passed the securities exam with a 90+% grade, did not actually make me more qualified in selling those products. Actual knowledge of the products and the "experience" marketing such products is of utmost importance. There should be an apprentice requirement to work with a seasoned broker for a few years first, before being allowed to sell variable products to clients. This is the area where I believe many products are sold that clients complain about.

RE: FIA's, possibly there should be a knowlegde check from the insurance company that the agent understands the particular FIA before they are appointed. Do they understand and can they explain the various indexing methods so the client can understand.

I vote NO to FIA's being a security.