Subject: File No. S7-14-08
From: RONALD L LAMBERT, CLU
Affiliation: TRUST DELIVERY REP

July 8, 2008

After 38 years of continuous sales and management experience in both the Insurance and Securities business, I am surprised and angered that regulators are attempting to control a part of the insurance business by mistaking an insurance product for an investment.

A product that has guarantees is not at risk...and a product with any risk cannot be guaranteed. Insurance contracts have total principal guarantees. Investments contracts are characterized with risk that includes possibility of 100% loss of principal.

Stop the insanity. Hire some professionals and get educated. Most state regulators are fully capable of protecting the consumer. The SEC has plenty of work to do for the investor before expending resources to ultimately over-reach their capacity to understand and regulate the insurance business.

Please contact me for further comments or input at 614-799-8729 or write to me at P.O. Box 626 Worthington, OH 43085. Stop the insanity.