Subject: File No. S7-14-08
From: willie l gillis, Ph.D
Affiliation: Financial Planner

November 17, 2008

SEC RULING 151a IS UNFAIR, UNREASONABLE AND I QUESTION EVEN THE PROPOSITION OF THIS ENTIRE MATTER. THESE ARE INSURANCE PRODUCTS NOT SECURITIES AND SHOULD CONTINUE TO BE TREATED AS SUCH. THE SEC HAS NO BUSINESS INTERFERING WITH INSURANCE TRANSACTIONS IN ORDER TO LINE THEIR POCKETS AND CAUSE FINANCIAL HARDSHIPS FOR THOSE LOOKING FOR ALTERNATIVE WAYS TO PROTECT THEIR NEST EGGS FROM STOCK MARKET LOSSES. THIS RULING JUST ISN'T FAIR AND UNETHICAL, AND I FIND IT COMICAL THAT THE VERY COMMITTEE THAT HAD OVERSIGHT OF THE SECURITIES MARKET TODAY HAVE TOTALLY NEGLECTED THEIR RESPONSIBILITY AND REEKED SUCH TREMENDOUS HAVOC ON INNOCENT PEOPLE THAT PUT THEIR TRUST IN THEM. I AM OPPOSED TO THIS RULING, PERIOD.