November 14, 2008

Subject: File No. S7-14-08

I am a financial planner and member of the FPA. I strongly support the proposed SEC rule. I have seen the aftermath of far to many inappropriate variable sales. These products are investments and must be regulated as such.

Steve Popelka, CFP(r)
Financial Advisor
First Command Financial Services, Inc., parent of
First Command Financial Planning, Inc.