Subject: File No. S7-14-08
From: Barry L Hamilton
Affiliation: CEO Hamilton Financial

October 16, 2008

As a licensed insurance agent and a registered rep, I do not understand why the SEC wants to take over jurisdiction of FIA's. A FIA is a fixed guaranteed product, not a security such as mutual fund or variable annuity. In todays volatile stock market where people have seen their investment portfolios wiped out, all my clients who have FIA's have not participated in any stock market losses. Why would you want to turn this product into a security where people could lose in a market downturn?

Barry L Hamilton