Subject: File No. S7-14-08
From: michael t kennelly, mr

July 14, 2008

investment risk There is no investment risk to the client as they are not purchasing shares in any security nor does the account fluctuate in market volatility.The clients who purchase FIA's are looking for guarantes not found in Mutual funds ,stocks or variable annuties.Once interest is credited to a FIA it cannot be reduced by market volatilty.

A professional life insurance agent is well equipped to determine if a FIA is best suited for a particular client . This is done through regulations by the insurers and through state mandated continuing education credits

Commissions earned are very similar to that of an advisor or fund manager.

Please reject this proposed rule 151 as millions of Americans are looking for a safe and alternative option for their money . Let the life insurance profesionals do the job they were trained to do .