Subject: File No. S7-14-08
From: NAWANA E ROSS, MS
Affiliation: LIFE INSURANCE AGENT

August 8, 2008

Costs of creation and administration of the product will increase dramatically and reduce the value for FIA purchasers.

or purposes of the Small Business Regulatory Enforcement Fairness Act of 1996, this constitutes:

1. A major effect on the economy of $100 million or more.
2. A major increase in costs or prices for consumers or individual industries and
3. A significant adverse effect on competition, investment or innovation.