Subject: File No. S7-14-08
From: Michael F DeVito, Sr

September 11, 2008

FIAs are insurance products – not securities.
Sales practices: Suitability, disclosure, and agent practices in our industry have evolved significantly over the last five years and provide substantial consumer protection. The Rule Proposal, as written, would not considerably improve consumer safeguards.
Agent licensure: I do not believe a securities license should be required to sell FIAs.

I am against and oppose SEC Rule 151A