Subject: File No. S7-14-08
From: Keith B. Sistad
Affiliation: Insurance Agent

September 3, 2008

I strongly oppose proposed Rule 151A. This is an insurance product and the Insurance Depts have done great job of regulating these products. They have had to make adjustments as these products gained in popularity, but they have done that and will continue to do so. Also I feel this would add another layer of beauracrocy to this product which is not necessary. The more paper work you put in front of people the more you confuse them. Paper work only protects the companies as they can say" well you signed the form". Lastly there is no market related down side risk to these products so why should they be considered a security? If you would like to discuss this further my phone # is 218-435-2764 or cell phone 701-367-5614. Thanks, Keith.