Subject: File No. S7-14-08
From: Laurie B Prevette
Affiliation: RHU, LUTCF

September 6, 2008

The SEC approach of using Rule 151A to declare FIAs as securities would have far-reaching consequences by disrupting the distribution of these products. This dramatic change would carry fewer consumer protections at the tremendous cost of limiting competition by compromising customer choice and adding an unnecessary additional regulatory layer to the sale of these popular products.