Subject: File No. S7-14-08
From: John P Crotteau, CSA

August 27, 2008

1. FIA's are purchased for the lack of risk involved and the guaranteed returns. There is no security that can meet those criteria.
2. The purchaser of a FIA bears NO risk. The insurance company takes the risk.
3. The purchaser assumes NO risk but can be rewarded if the indexes show improvement.
4. The insurance regulators in the states and the insurance companies have shown that they are concerned about suitablility and make certain that the client understands the terms of the policy.
5. Although the initial commisssions are quite satisfactory, over the life of the contract , they are small compared to securities and mutual funds.
6. There is NO case law that supports that a FIA should be considered a security or even comes close to being a security.
7. Making a FIA a security will decrease the competition, the number of agents and the availablilty to seniors and other buyers. They will then be directed to risky security products.
8. Because of the lower competitive situation, costs will increase.
9. As of right now, seniors assets are better served by the no risk and guarantees of a FIA.

FIA's SHOULD NOT BE CONSIDERED a Security product..