Subject: S7-14-08

August 27, 2008

Dear Secretary,

These remarks are being dent to voice our strong objection to Rule 151A.

My firm is a 47 year old insurance agency, that I founded in 1961. In 1988 - twenty years ago - I decided to take my agency in the direction of providing expertise exclusively in the fixed product marketplace. Fixed products are defined as traditional life insurance, disability insurance, long term care insurance, fixed, and indexed annuities. Fixed products do not include variable life insurance or variable annuities.

Our main focus is to provide agency support, and fixed product alternatives, exclusively to insurance agents, and brokers, financial planners, and financial institutions. Because we don't compete with these financial professionals, they do business with us. Our firm acts as a "Back Room". Without their business, our agency would find it impossible to stay in business.

A significant percentage of our agency's revenue is generated through the sales, and service of fixed indexed annuities sold and serviced by these agents, brokers, financial planners, and financial institutions. If your proposed Rule 151A is permitted to become effective, it would effectively put us out of business!! I find it impossible to believe that you intended the consequence of putting small businesses, like ours, out of business. And yet, that would be tragedy of your action. Consider that our firm is but one of thousands that would unfairly put out of business if Rule 151A is allowed to become effective.

One of the reasons we decided to go out of the equities business, in 1988, was because we did not wish to be a part of the uncertainty that attaches itself to securities, and related products. Our intention then, and still today, is to provide GUARANTEED security to the people, families, and businesses that do business with us. Fixed indexed annuities are products that provide GUARANTEES to the customer. Because the product eliminates the possibility of loss of principal, through GUARANTEES, it does not qualify as a security. The SEC long ago ruled that the fixed index annuity was not equity. That fact has not changed. What the SEC is trying to do is supervise a product that is not an equity investment, because of a sensational television program. And, in the process will potentially wind up putting thousands of small businesses, like ours, out of business, and in many cases into bankruptcy. This will be the tragedy of the over reaction to a television program.

In the strongest language possible, I petition you to withdraw Rule 151A, and permit my company, and thousands like ours, to remain in business without your interference. The insurance Regulators, Superintendents, and Commissioners, in the U.S. have long been effective in providing protection to the insurance and annuity buying public. The best posture you could take is to remove Rule 151A, and continue to allow the regulatory bodies, already in place, to continue their excellent work.

Sincerely,

Larry A. Kaufman, President
Kaufman Financial Services