Subject: File No. S7-14-08

November 3, 2008

Gentlemen:

I am at a loss on a few points I would like clarification on.
Why is the SEC so strongly behind proposal 151A?
Clearly, indexed insurance products are not invested in any stock related market as the index is elected solely as a payment method for the consumer.

As a sales professional, getting another license is not a major item as clearly the securities Brokers will not sell these products simply because they will not produce the greatest financial benefit for them.

Further, by limiting the public availability to these beneficial programs, the only group who really loses are the consumers. This is definitely not something I cannot support.

I noticed the extremely short review periods and timing (immediatly post-election). Any observer might note that the SEC was trying to railroad a proposal through as opposed to thoroughly reviewing the programs involved.

I would welcome a discussion opportunity to view the real issues.

Regards,

David Ireland