Subject: File No. S7-14-08
From: Matthew R Wolfe, CPA
Affiliation: AICPA

July 30, 2008

Dear Sir or Madam,

This is to express my support for this new rule as I firmly believe that it will close a critical loophole in our securities law created when this product was created by the insurance carriers several years ago.

As a CPA, Registered Rep and Registered Principal (Series 7 and 24), I consider any product that ties product performance to a market index is in essence a security. This is no different that any other type of derivative where the value of the investment is tied to some other outside security or commodity.

I personally have witnessed non-registered insurance agents openly talking about how this product gives them ammunition to compete against other agents who also take the effort to be securities licensed. To me this product was created by insurers to "throw a bone" to their non-registered ranks that could not sell Variable Universal Life or VA's.

As for guarantees, most products in this classification do offer a "floor" but are almost always illustrated with non-guaranteed values.

Net, I require all of the reps that I supervise to sell these with the same care as if they were selling a security. The balance of the industry should do the same.

Best regards,

Matthew R. Wolfe, CPA / PFS