Subject: File No. S7-14-08
From: Richard M sazonoff

August 28, 2008

To whom it may concern: I believe that rule 151a does not serve a constructive purpose for consumers and would if adopted inhibit choice for persons who seek safety for their hard earned dollars.

I have been an insurance broker for twenty five years and I am also a registered representative for variable products.

Most of my clients are retirees, teachers, or small business owners. Generally these people seek safety of principal as their number one goal for their money. Insurance companies fulfill this role well, unlike investment companies.

During the great bull market of the 1990's I offered variable annuities and mutual funds to many of my clients as it was difficult at that time for anyone to conceive of the market correction of 2000-2002. Since that time, I have found an increasing number of retirees as well as baby boomers, who simply cannot stand to lose their principal.

Although I believe I was thorough in my fact finding and almost always recommended balanced portfolios within my variable product sales, I know that certain clients did lose principal due to their choices of more aggressive portfolios. Since I have been offering fixed indexed annuities, I have had no clients lose money and have had no client complaints about these products. And of course there has been no SEC rule 151a to be concerned about.

I have come to realize that for many such clients, the fixed indexed annuity is a wonderful alternative to CD's and money markets and it is the type of product that fits a niche. It is absolutely not comparable to variable investment products which do not emphasize savings but glamorize high returns. Since insurance companies bear the risk for the non-guaranteed aspects of fixed indexed annuities, consumers feel safe knowing that the guarantees of principal and minimum interest will be there throughout their policy term.

It may be true that some agents have abused their positions of trust by not revealing policy surrender charges or stating incorrectly that great investment performance is assured by these produts. But these are not reasons why fixed indexed annuities themselves should be characterized in the same way as securities subject to SEC regulation.

It is simply not appropriate for the SEC to consider these products in the same vein as variable products. I have read prospectuses and I am confident that most consumers do not, yet these same consumers often complain when their investments decline in value. Fixed indexed annuities are not sold by prospectus. Although the SEC regulates variable products sold by prospectus these products cannot guarantee principal for these investments.

As I understand it each state has its own regulatory authority with an insurance commissioner at the helm to provide oversight and consumer protection.

By overriding this exisiting system of checks and balances, the SEC has not offered sufficient reasons why their oversight would be preferable to the current system. I recall countless examples of variable products creating massive losses for consumers yet all of these products had SEC oversight at inception.

Whatever the reasons, I hope that cooler heads will prevail and rule 151a will go into the dustbin of history.