Subject: File No. S7-14-08
From: Pamela J Griswold
Affiliation: Life Insurance Agent

July 13, 2008

-This just doesn't make sense. When you are guarantee to a client for a fixed period of time, and then how much will be added to the prime, and that virtually in this manner there is little risk, then we are not submitting them to pick particular markets, then this is NOT involving a registered product. It is our concern to be sure that the customer understands that there is "less risk" and that is what the client is looking for, then you should not need to be registered in order to sell a product that is not risky.