Subject: File No. S7-14-08
From: Richard J Alford
Affiliation: CEO Alford Advisory Group

August 28, 2008

Fixed Indexed Annuities.

FIA,s are very popular with retirees. My clients purchase this product to preserve principal. In short to eliminate risk which is associated with investments such as mutual funds, stocks, bonds, etc. Purchasers are not impacted by market fluctuations. Our clients like the fact that their principal and past interest credits are not reduced by market fluctuations.

If an FIA owner has a complaint the State of Texas has a Department of insurance which handles such complaints without requiring the use of attorneys by owner. Unlike the SEC's requirements.

Accord to the judge, Malone V. Addison FIA is not a security. Why bring brokerage companies into this? They have cost the retired working people eight to ten TRILLON Dollars in the last ten years. It is very expensive to purchase products through stock brokers. Why put extra expense on the retired working people? If this is not the case just look at the variable annuity. I have even read articles produced by the SEC warning the public about the expense of these products. The brokers continue to dump these annuities on the unsuspecting public unchecked by the SEC.

What you are proposing violates the Small Business Regulation Fairness Act of 1996 by imposing unnecessary expense on the insurance industry.

This act is clearly not in the interest of the consumer but is strickly a political move in favor of the brokerage companies.