Subject: File No. S7-14-08: Proposed Rule 151A

September 9, 2008

Please add Physicians Life Insurance Company to the list of those who are respectfully requesting an extension of at least 90 days to the September 10, 2008 deadline for comment on the captioned proposed rule.

The September 10 deadline has not allowed us time to fully consider all the impacts the proposed rule would have on our various products, administrative systems, etc. Our analysis to date tells us, however, that the impacts would be significant and, therefore, deserving of our best thoughts and detailed comments. Those will, in turn, allow the Commission to have all the best information available before a final rule, if any, is established.

Your consideration of our request for an extension of the comment deadline for an additional 90 days is greatly appreciated.

Phil Powell
Vice President, Government and Industry
Physicians Life Insurance Company