Subject: File No. S7-14-08
From: Mark R Wallace
Affiliation: Licensed Independent Insurance Agent

September 2, 2008

My livelihood and business as a licensed, independent insurance agent may be greatly impacted by a proposed rule 151A recently published by your commission. This rule adds no consumer protections not already provided by state insurance regulations and would in fact undermine many state initiatives concerning sales practices. The Securities industry has much to gain from this ruling and Im not sure that consumers have anything to gain at all. These products provide consumers with much needed principle protection that variable annuities and other registered securities can not. Please reconsider this ruling.

Sincerely,

Mark Wallace