Subject: Proposed Rule 151A - File #S7-14-08

August 29, 2008

I am a FINRA Series 7 Registered Representative & licensed insurance agent in the state of Michigan. I am writing IN FAVOR & SUPPORT OF the adoption of proposed Rule 151A. I am not concerned, in the least, about the application of proposed Rule 151A not being limited to indexed annuities & that other annuity & insurance products that happen to fit the criteria set out in the rule would be brought within the scope of the rule.

While I am a member of NAIFA, with respect to this particular rule, I DO NOT AGREE WITH NAIFA’S POSITION. While many indexed annuities are tied to fixed income indexes, the majority that I have seen were tied to an equity index. To the extent that an insurance agent would discuss how the re-pricing of a rate tied to an equity index works, the insurance agent is discussing securities & ought to be licensed. Rather than segregate fixed income indexes from equity indexes, from a supervisory standpoint, I believe the product is complicated enough that the supervision of the SEC & FINRA would add an important element of protection for the consumer.

I am proud to say that New York Life does not allow its agents to sell indexed annuities. I support this position 100%. Perhaps, with the adoption of Rule 151A, & with an entire revamping of the product structure, sales, & regulatory oversight of indexed products, my company will take a look at them in the future. Even then, however, there are a great deal of negative perceptions, & realities of the past, to overcome.

I urge you to pursue the ADOPTION OF RULE 151A & to enforce the oversight of index annuities vigorously thru the SEC & FINRA.

Carolyn

Carolyn D. (Beene) Tyler, LUTCF
Financial Services Professional
Agent, New York Life Insurance Company