Subject: File Number S7-14-08

August 27, 2008

Florence Harmon
Acting Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609

Florence Harmon:

Ms. Harmon,

I am not in favor of SEC Rule 151A. Index Annuities do not look or act like securities such as stocks, bonds or mutual funds. They do not share the same risk as these other types of investments.

It seems Rule 151A is concerned with how EIA's are marketed, whether or not they are suitbale for a client and if proper disclosure is made. Those are not areas where the SEC should be involved as individual state insurance departments handle those issues. I'm also conderned that if Rule 151A is adopted other annuity products such as fixed annuities will eventually fall under the same definition. On the other hand, variable anniuties are very much like stocks, bonds and mutual funds and belong under the watchful eye of the SEC.

I am very much opposed to this rule and would encourage the SEC to back off from this rule and withdraw their proposal.

Thank you for your consideration.

Sincerely,

Michael R. Craigen