Subject: File No. S7-14-08
From: John W. Risley, Jr.
Affiliation: President, Owner and CCO of L.O. Thomas Co. Inc. B/D

September 16, 2008

Dear Sir,

I am an owner of a B/D with an unblemished record started in 1929. I have been licensed for 31 years.

I strongly urge the adoption of the proposed rule...If we as Broker Dealers are to be "gate keepers" and to insure compliance, we must be given the tools to do so. We must have qualified, highly competent professionals offering financial products and services. This rule needs to be adopted immediately and have an immediate effective date. FINRA and Broker Dealers need the ability to regulate the offering of investment products. Too many products can be sold without the knowledge of the Broker Dealer. If I am to be held accountable. I must be given the abilty to see that these products are appropriate for that particular investor. It is my opinion that all investments including Fixed, Immediate and EIA Annuities should be considered investment securities....

Sincerely,

John W. Risley, JR.
President
L.O.Thomas Co., Inc.