Subject: File No. S7-14-08
From: Joseph Weinkle, CLU
Affiliation: NAIFA, SFSP

August 14, 2008

I have been an insurance agent for 35 years. I have never been securities licensed, nor do I want to be at this late stage of my career. While I do not sell Fixed Indexed products very often they do fill a need for some people. At no time in my training about these products have I ever seen anything in the law or regulations which could legitimately classify such products as anything other than fixed.

Why do you insist on trying to muddy the waters about Fixed Indexed products? I am certain you have enough real work to do to protect the public from real dangers without having to manufacture more. Should you actually succeed in your quest it would mean taking away a group of products from qualified agents like me who would simply not sell them anymore. As an agent, speaker, and continuing education instructor I abide by the laws and rules of my state and any applicable Federal laws. There is no need for you to jump in here.

Thank you for your consideration.