Subject: File No. S7-14-08
From: Becky Halphin

September 2, 2008

I am a registred rep and I oppose this rule. It does not seem necessary to regulate a product that has a guarantee of no loss incorporated within the contract. As I understand the product it does not participate directly in the stock market. If that is the case - why regulate it with the SEC?

Look to get involved with products and/or services that have direct affiliation with the market. THis is just more unnecessary rules to govern something that is already overseen by other parties.

Stick to Sec business.

Thank you.