Subject: File No. S7-14-08
From: Richard D Garrett, LUTCF, FIC
Affiliation: President, Professional Insurance Associates, LLC

October 20, 2008

As an insurance firm marketing to educators' 403(b) and other retirement needs, we specialize in fixed indexed annuities. In recent weeks, many educators who were invested in market-based securities have seen their retirement funds severely diminished, while none of our annuity clients have lost anything.

It is my sincere belief that if our annuities are placed under SEC regulation, most licensed agents will turn back to life and health insurance sales rather than submit to the rediculous requirements placed on them by broker-dealers. In addition, putting broker-dealers in place supervising annuity sales will substantially reduce agent commissions, thereby further reducing annuity sales.

In short, I view the proposal to regulate fixed indexed annuities through the SEC as nothing more than a power grab by the equity industry which, if implemented, will reduce the sales of these valuable products to those who need them for retirement planning.