Subject: File No. S7-14-08
From: Robert Williams
Affiliation: LtCol (Ret), USAF and RFC

August 25, 2008

Ref 151a
This is a fixed product, contractual guarantee of no loss through variable investment. Since this is not a security, then it should not be regulated in the fashion the Securities Industry has suggested. I suggest that they are afraid of competition from fixed products and want to make them difficult to sell to gain and edge in the market place. They want the SEC to do their bidding and declare a fixed product a variable one so they can cut down on competition---NOT FAIR. You should see this for what it is, and just say "NO"
Respectfully