Subject: Proposed Rule 151A

August 28, 2008

To Whom It May Concern:

I have been an insurance professional for 30 plus years. In the past five to seven years, Indexed Annuities have become a significant part of my business, as well as traditional fixed annuities and life insurance. I do estate planning and oftentimes in estate planning, I need the safety and security of traditional annuities - of which the indexed annuity is - to provide stability for my clients cash needs at death.

Over the past fifteen years, more and more of my clients have put more and more of their necessary capital for estate planning into mutual funds, stocks and bonds. For many of my clients who died in 2001-2004, this proved disastrous. Hence, we have been using more and more of the fixed index annuities to provide stability.

I cannot get a series 6 or 7 license and continue to produce journal and newspaper articles about the intricacies of planning.

An index annuity is not an investment - it is a guaranteed savings instrument with guaranteed values. No true 'investment' has these characteristics. Clients understand, when they use an indexed annuity, the principal is guaranteed (subject to early surrender charges as is many CD's). They also understand they have the option of placing their funds in the fixed bucket, or the index bucket to determine what interest rate will be paid upon their principal. After each year, the gain or loss from the previous year is reset and the client again has the option of fixed or index based returns. Banks also must set their savings rates based on a variety of similar indexes and costs. A person who uses an index annuity is a 'saver' - one who is guaranteed his or her principal and a guarantee of keeping any interest rate return as well.

An investment, by definition, is purchasing something you deem to be a fair value and hope that between the returns paid on the investment i.e. Dividends, interest, etc or the hope that someone will decide your purchase is more valuable to them what you paid for it and they tender an offer to purchase it from you at a higher, or sometimes, lower value. An investment is a gamble of principal and return and is not a savings instrument, but a desire to have someone pay you more than what you paid. That's money making - not money saving. No one is ever going to approach a Fixed Index Annuity owner and offer them more for their FIA than what they paid for it and have accrued within it's account value.

Comparing savings - such as FIA's - to any investment is like comparing race cars to watermelons - they simply don't belong together in the same context.

If agents have been knowingly misrepresenting how these products are designed, they should be prosecuted to the full extent of the law. I find many agents really are not properly trained in the design of FIA's to be properly selling these products. I also find a lot of brokers selling variable annuities and misrepresenting them as well.

However, misrepresentation does not define an investment from a savings instrument! Only guarantees separate savings instruments from investments.

Sincerely,

Michael Baron
Great Plains Diversified Services, Inc.