Subject: File No. S7-14-08
From: Varsha Grogan
Affiliation: FLMI

September 4, 2008

I oppose the proposed rule 151A because I agree with the position that NAILBA has taken and all the agruements laid out there already. I am personally licensed to sell only fixed products since I do not like the volatility in the variable market. When a product has no downside risk except on early surrender, the sales of these products require suitabilty tests rather than more regulation.