November 17, 2008

Subject: File No.s7-14-08

As a Certified Financial Planner who has been in the investment/financial planning profession for the past 25 years, I urge you not to drop this rule. From my experience, most of the clients who have had problems with the Index Annuities as well as the Variable Annuities have been sold by insurance agents with series 7 license. Bringing this under Federal scrutiny should be a big help in curtailing these problems. This is my opinion only and not necessarily the opinion of my employer.

Gary A. Tilley, CFP, AAMS
Investment Officer, Vice President
First Tennessee Brokerage, Inc.