Subject: File No. S7-14-08
From: Bart Kreiss
Affiliation: Independent Insurance Agent

October 31, 2008

RE section 151A.

This would classify Indexed annuiities and life insurance as securities. They are not securities they are flexible interest earning insurance contracts. They are not based on market risk and therefore do not operate as securities. With these contracts clients are eliminating risk. I specifically began selling these types of insurance so as to insure the client having a positive outcome. I gave up my security licenses because I was tired of exlpaining to my clients why they lost money.