Subject: File No. S7-14-08
From: Michelle K Seward
Affiliation: Insurance Agent/ CEO Protege Fin Ins Services

July 11, 2008

I am the CEO of a small General Agency that employees about 25 life agents. We specialize in Indexed annuities and Indexed UL for the main purpose of giving our clients an investment that has a guaranteed principal but an average of a higher rate than traditional annuities. As with any industry, the few unethical agents (just as there are unethical brokers)have sold these products with poor disclosure. That is not the case with my agents or this firm. Our clients are extremely happy with their products. It would cause my company to lose money and my agents if these became a regulated investment. Furthermore, what are you basing it off of? This is an insurance product with a guaranteed principal, a guaranteed interest rate over the length of the contract and offers all of the benefits of an annuity. My clients have had returns as high as 15% with a guarantee on their principal and no chance of losing the interest credited. A wonderful product that should stay as an insurance regulated investment.

Sincerely,

Michelle Seward