Subject: File Number S7-14-08

August 28, 2008

To whom it may concern,

Regarding Rule 151a

I was a registered representative several years ago, and am currently a Registered Investment Advisor, so I have no axe to grind against securities.

However, I’m completely puzzled by rule 151a. What is the basis for reclassifying this product as a security?

1) The SEC has already ruled that index annuities are fixed products.

2) They are guaranteed products. They do carry liquidity risk, like many other savings or investment vehicles. They also carry interest rate risk. However, most of these products carry no market risk - the client cannot lose principal or interest.

This leads one to wonder what motivation would prompt such of decision. However that’s not why I’m writing. I’ll leave that question to those who are vocal & confrontational.

My biggest concern is this. One of the reasons I have read that supposedly justifies this decision is that if the SEC regulates these annuities, then brochures and disclosures will be simplified for the client’s sake. Have you ever read a prospectus…all the way through? I have zero confidence that these products would be marketed more clearly than they are now. My concern is that it will only add complexity and confusion to the marketing, sales, underwriting & reporting process. NO THANKS!

If you are still reading…thank you for taking the time to consider one opinion.

Craig Anderson