Subject: file #S7-14-08

August 28, 2008

I totally agree with the Proposed Rule 151A. There are way too many agents selling indexed annuities who have no idea of what they are doing and are hurting their clients. This product is very complex and supervision by the FINRA and the broker dealers would be a good thing

Richard H. Villavaso, CLU,ChFC
General Agent
Guardian Life Insurance Company of America