Subject: File Number S7-14-08

August 28, 2008

Dear Sirs:

I was contacted by NAIFA about opposing Rule 151A. I am a Registered Rep with MML Investor Services and am constantly called on to solicit Indexed Annuities. While some of these products may be appropriate for some people, my concern is that the product is often misrepresented and totally misunderstood by most clients. For example, even the wholesalers who call me to try to get me to solicit an S&P 500 Index Annuity are unaware that the Index does not include the dividends which make up over 40% of the return of the S&P 500.

I had one client describe the product he had bought as "heads you win, tails you don't lose". He was totally unaware that there was a significant surrender charge. When the public buys products like indexed annuities, I think their expectations are inflated by untrained agents interest primarily in generating high commissions, and they will ultimately be disappointed and become disenchanted with everyone in the insurance industry.

I therefore support Rule151A which promotes more scrutiny of these products and the agents that market them.Thank you for the opportunity to let me share my thoughts.

Tim Ebert, CLU, ChFC
EBERT FINANCIAL

BUILDING BETTER FINANCIAL SOLUTIONS