Subject: File No. S7-14-08
From: John W Felton, IV
Affiliation: LUTCF

September 4, 2008

I strongly object to the SEC's proposed rule for the following reasons. The risk that the SEC speaks of is in no way similar to a mutual fund or other investment vehicle. The contract has guarantees that are NOT available in mutual funds. That guarantee is a benefit to the consumer. Also by changing the rules, the number of carriers who offer this product will decrease thus negatively affecting the consumer.