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:

I am a licensed insurance and financial professional. I am writing to you because I oppose the adoption of proposed Rule 151A, which would classify most indexed annuities as securities. I believe that there are serious concerns that need to be addressed about these indexed annuities, but those concerns should be addressed by the insurance regulatory bodies.
Properly structured indexed annuities do not share the same investment characteristics as investment products such as mutual funds and individual stocks, and they should remain classified as insurance products.

I urge the SEC to withdraw the proposed rule. Thank you for your consideration.

Sincerely,

Mel Pine