Subject: File No. S7-14-08
From: Narlene G. Capron

October 31, 2008

As an agent who held an NASD license previously, I cannot understand the reason or purpose in classifying FIA's as securities. My understanding of the main definition for securities is the keyword "variable", which puts clients' principal funds at "risk". The main definition for a FIA is the keyword "fixed", which puts clients' principal funds at "no risk". I relinquished my NASD license years ago, because I chose not to jeopardize my clients' retirement funds. Today, with the volatile stock market, I am very happy I made that decision - my clients are even more happy. I have heard agents with security licenses comment that they want this proposed ruling passed in order to run off non-security licensed agents and narrow the playing field. We have enough unemployment in this country.