Subject: File No. S7-14-08
From: James Clous
Affiliation: Financial Advisor

August 25, 2008

Yes, I agree with this suggestion to consider the fixed annuity a security. It clearly is one. The main issue is insurance agents are advising people to sell SECURITIES and buy fixed annuities usually because they can't sell securities and they make very large commissions when selling fixed annuities. Most of these fixed annuities have very long CDSC periods and the senior citizens can't correct a bad decision once they purchase these products. Also, most of them have very poor returns (usually zero). I don't see how the insurance agents can make a recommendation to sell securities when they aren't trained and/or licensed to do so. This new rule would change that situation.