Subject: File No. S7-14-08
From: William P. Smith

October 29, 2008

Rule 151A would cause tremendous cost to the Companies to regulate. You can see the difference in the expenses of VL and WL and VUL and UL brought on by the cost of the regulatory requirements mandated to the companies. FIAs do not have the same market swings that securities and mutual funds have so why regulate them like they do. FIAs are already regulated by state insurance depts. How can the Federal agency do a better job? Has this been proven by the goings on in our present day economy, our present day stock market and the present day action of Wall Street? Rather than taking on more responsibility I think the American Public would like the SEC to be able to fulfill the duties they already have.