Subject: File No. S7-14-08
From: david ireland

November 14, 2008

What exactly is the SEC's motivation to declare an insurance product, clearky NOT invested in any stock related market, a security?

-It does not meet the definition of a security
-It does not serve to further protect any consumer
-It does not foster business growth among the private sector

What then does it do?
-it does further regulate an already highly regulated industry
-it does remove competititive obstacle from SEC constituency
-it does reduce consumer protection and savings options.

Is this worth it just so the SEC can gain some level of seni-control over the insurance industry?

Honestly, gentlemen.