Subject: File No. S7-14-08
From: James C Lang, II

August 21, 2008

In my opinion the SEC is considering 151 due to pressure from Broker Dealers in this country. They are losing precious dollars to the FIA Industry because of guarantees they can't or won't match. If there is actual risk to an Individual's Principal then I would agree that it is an actual Security. However since there is no Risk to the Principal I do not beleive it should be considered a Security. Annuities are continually evolving and I now beleive should be a part of every persons pre-retirement and post retirement plans. When I first entered this business in 1980 I did not believe in Annuities or there value in the future. Now with the lack of Defined Benefit Plans out there and the very possibity of outliving a persons assets FIA's are a very prudent asset for retirement. Since it is considered and Insurance Product I do not believe it should be regulated by the SEC. As a former Registered Rep I firmly believe that invlovement from the SEC would just water down the products due to the added costs of being a regulated product. There already enough oversight at the State Level.