Subject: File No. S7-14-08
From: Frederic H Schilling
Affiliation: COO

July 30, 2008

I make a living selling indexed annuities. I have impeccable ethics standards. I am opposed to your desire to control the sales of these insurance products.
I think you need to spend more time and money regulating your existing brokers and leave insurance to the Dept. of Insurace.

I have tried on three occassions to pass your IAR Series 65 unsuccessfully. You will deprive me of employemnet if you pass this ruling.

It appears to me the SEC has all they can handle with Wall Street. If you have a problem with the marketing of the products then fine, request changes.