Subject: File No. S7-14-08
From: Danny Harlow

August 14, 2008

FIA should NOT be considered a securities product because it isn't. I, for 35 years, have been advising my clients about their retirement assets. Being and RIA, registered investment advisor, allows me to assess the problem and suggest the solutions that people have. now that I and my clients are getting close to or at retirement I will always lean towards safety and preservation. The FIA provides this with guarantees. I know of no other securities that will provide safety and guarantees, they ALL have an eliment of risk and a retiree cannot afford to take as much risk during the deculmulation stage of life. Therefore, I totally believe in and supporty the FIA but it is NOT and should never be considered a securites product. The broker/dealers and SEC and FINRA should have better things to watch for than this issue. My suggestion is a mandatory CE course required of everyone selling the FIA on a every two year basis. Companies should support this training and even hold commissions on those who have not passed this training. It is NOT the product that is the issue, it is the untrained salesperson not going through full disclosure.