Subject: File No. S7-14-08
From: Tracy W Mitchell
Affiliation: President, Guidepost Financial LLC

August 26, 2008

I am series 65 and life licensed. I have been licensed since 1995. The majority of my clients are of retirement age and seek safe harbors for their retirement funds. They steer away from investments that carry risk of loss such as variable annuities, mutual funds, stocks. They gravitate toward safe instruments such as CDs, money markets, saving accounts and fixed or fixed indexed annuities. Fixed indexed annuities do not carry market risk. My clients that own fixed indexed annuities have never lost money in a down market and have made gains in an up market, they can also choose a guaranteed fixed rate or both. The fixed indexed annuity was designed for those that do not want risk. Catigorizing an FIA as a security would not be in the best interest of the consumer and should remain what it is. A no risk life insurance product.

Sincerely,
Tracy Mitchell
Registered Financial Advisor