Subject: File No. S7-14-08
From: Jerry J Rogers
Affiliation: President of Retirement Solutions, a Registered Investment Advisory Firm

November 7, 2008

As a 24 year veteran of the financial services industry I have strong objections to the securities industry's desire to bring Fixed Indexed Annuities under its "protection". Fixed Indexed Annuities are not securities. Fixed Indexed Annnuities do not put the client's money at risk the way securities do. What would be next - the securities industry deciding they want to regulate certificates of deposit at the bank? I have seen the value of fixed indexed annuities for my clients and I have seen the lack of ethics amoung the securities industry's higher echelon. No one would win in this scenario - the securities regulators would cause much more harm than good. The fact that a tabloid television news story was used as "evidence" that the public needs heir "protection" should be a warning that something is not quite right with this whole proposal. Please leave this issue alone.