Subject: File No. S7-14-08
From: Theo H Woods

October 28, 2008

I am having trouble understanding why the SEC would want to regulate an investment that does not require a prospectus. To my knowledge no one has ever lost any money due to market performance on these investments. Although they do contain invesment choices that need to be explained the principal does not fluctuate no matter which options you choose.

I see no need for the SEC to regulate this product.