Subject: File No.
From: James K Finster
Affiliation: President, Cyan Insurance Solutions, Inc.

June 2, 2017

Our firm is not securities licensed, we are insurance only. In discussions with DOL, we would ask that the SEC raise the issue of Fixed Indexed Annuities (FIAs) being Prohibited Transactions, and needing BICE or PTE-8424. These products are NOT securities. The draft DOL rule did not include FIAs, but the industry was hit with a curve ball when the final rule was issued.