Subject: File No. S7-14-08
From: Dean L Stewart
Affiliation: CFP.

August 26, 2008

Dear Sirs:

This change will cause a negative economic impact well in excess of $100 million to small agencies within the insurance industry. This violates the Small Business Regulatory Enforcement Fairness Act of 1996.

As I am a small business man in the insurance industry for the last 33 years I feel that you should not pass this regulation for FIA's are a fixed product and people purchase the product for many of the same reasons people purchase saavings instruments such as CD's or Fixed Annuities.

The SEC suggests that FIA purchases bare the majority of investment risk for flucting market performance. FACT:
Unlike true secirity products, the purchaser is NOT directly impacted by market flutuations. Negative investment risk fluctions to the purchaser is eliminated entirely.

Please DO Not Pass this Regulation.

Sincerely,

Dean L. Stewart,CFP.