Subject: File No. S7-14-08
From: William P Kelly
Affiliation: MBA - CEO - Ins. Broker

August 1, 2008

Comments:

How can you consider an FIA a security? That tell thousands of us that you don't have a clue to what it is. Being of intellect, please research it before you judge it. If your only view of an FIA is that of FINRA, you have a lot to learn. Study the FIA, learn what it is, and what it's not. Learn how the Fixed Indexed Annuity protects the senior investor and the opportunity it gives them.

FIA's offer retirees opportunities of a risk free retirement with a better return than they receive from CDs. FIA's gives seniors an option to risk. Why would you want to make the only choice seniors have for decent returns securities, exposing them to risk?

If you put the FIA in the hands of BD's they will kill it. SEC, that just doesn't make sense, and just isn't the right thing to do.

Please reconsider your position, and judge the FIA to be a true insurance product and not a security.

Thank you,