Subject: File No. S7-14-08
From: Christopher L Wholehan

September 4, 2008

I find it insulting that the SEC is trying to regulate an unregistered product due to a few bad apples misrepresenting the policies - either maliciously or naively. There are just as many bad VA presentations as there are bad IA presenations - maybe the SEC should focus on the bad apples in their own jurisdiction.

The real issue is one of money exchanging hands from registered product to non-registered product, and the securities industry losing a lot of revenue from the transfer. So "if you can't beat them, rule them" they say. This is a blatant overstepping of bounds that needs to be fought to the last degree.