Subject: File No. S7-14-08
From: William G Avon, Jr.
Affiliation: LUTCF, Independent Broker

August 25, 2008

If the gov't is trying to regulate the industry because of some "bad eggs" and their marketing tactics, there is no need to have a series license as the "bad eggs" can get one just as easy. That is NOT accomplishing the task. Anyone can study and take a test for a license. There is NO reason or need to require fixed life producers to obtain additional licensing, B/D affiliation, additional paperwork, etc. It ONLY HURTS THE GOOD AGENTS. Stop the madness and enforce the best marketing practices so those agents who are misrepresenting the product, have to pay penalties and the IMO's they are affiliated with are more responsible. Add an additional client suitability form. Create a consumer protection booklet that the client has to sign off on that they will read. An additional license won't stop the problem. Better enforcement under current licenses will. Don't penalize the good agents, punish the bad.