November 17, 2008

Subject: S7-14-08

My Name is Pearline D. Smith. I have been an Insurance Professional for over 12 years total. I have always taken my fiduciary responsibility very seriously and have always taken pride in doing my job the right way. I never make a recommendation until I know that it fits with what the clients’ goals and needs are for their retirement money. Then with the recommendation I go through the full Acknowledgement of Disclosure. I am very detailed in every aspect of it from the accessibility or liquidity to the early withdrawal penalties. If the client has need of more money than is allowed under the free withdrawal I will tell them that the product is not suited for them. I understand that their may be a few complaints of bad apples who do not follow the guidelines but even if the guidelines are changed their will still be those who break the rules. I am proud of what I am able to do to protect people’s assets from market loss. Mr. John MacDonald of Graniteville, SC were in my office a few weeks ago and told me how happy he was that he was able to sleep at night knowing they he was no longer losing money. I have had dozens of phone calls over the past months from clients saying that they appreciated our seminars and experience in helping them transition from wealth accumulation to wealth protection and structured income. This is a very viable product and does not have market risk and therefore is not a security. I have prided myself in providing for the well being of my clients assets and that should not change.

Sincerely,

Pearline D. Smith