Subject: File No. S7-14-08
From: Michael Musarra
Affiliation: CEO, Purity One Investors Inc.

August 26, 2008

I strongly oppose the above mentioned proposal as it is an insurance product and not a security product. The SEC has always tried to father the insurance industry and the above proposal is a perfect example of that. FIA are in fact annuities for the sole reason that they have principal guarantee and the return that is recieved at the end of the year is only a portion of what the whole market has earned, not a specific stock or mutual fund. Not to mention that the insurance company is the one that manages the FIA, NOT the CLIENT. I believe the sole reason for the SEC to be inquiring on FIA is because they see the popularity of this product and they want a piece of the action.

Thank you for your time, these are all just my opinions on this subject matter.

Respectfully submitted,