Subject: File Number S7-14-08

August 27, 2008

I TOTALLY AGREE that the SEC and FINRA should have authority over indexed annuity sales, and someone who wishes to market/sell indexed annuities will need a series 6 or 7 securities license and be required to have IA sales supervised by a broker/dealer. An insurance producer license, by itself, should no longer be sufficient.

IA are based on stock and bond market returns and performance and thus should be governed by the Securities Act of 1933. In my opinion indexed annuities should NOT be continued to be treated as insurance products.

William L. Nichols, CRPC®
Chartered Retirement Planning Counselor
First Financial Group of the South, Inc.