Subject: File Number S7-14-08

August 28, 2008

I am a licensed insurance professional and financial advisor/financial planner. I fully support Rule 151A insofar as classification of Equity Indexed UL and Annuities as securities. They are far too complicated and have too many securities related issues related to them to be effectively marketed by people without securities licensing, training, and supervision.

I realize that one of my member organizations (NAIFA) is against this move. That said, I speak personally for their classification as securities.

My contact information is below should you have any questions.

Warm regards,

Mike Shipman

Michael L. Shipman
Financial Adviser
Shipman & Associates, LP