Subject: File No. S7-14-08
From: MELODIE K MCAVIN

August 27, 2008

Proposed Rule 151A creates a new unnecessary layer of regulation that will cause consumer confusion and economic disruption. The consequences of the SEC taking on a regulatory role of fixed index annuities over the current system of state regulation and oversight are likely to confuse consumers about what constitutes a market-risk security. The required changes for insurance carriers and producers will dramatically increase costs for those who sell and buy these annuities.

Signed,
Melodie K McAvin