Subject: File No. S7-14-08
From: Barney Chan

September 2, 2008

I am an independent insurance agent helping people using fixed index annuities. My livelihood and business as a licensed, independent insurance agent may be greatly impacted by a proposed rule 151A recently published by the Securities and Exchange Commission.

Rule 151A focuses on fixed index annuities, which are fixed annuities regulated by the state department of insurance and sold by licensed insurance agents such as myself. The SEC is seeking to require that all fixed annuities become registered products sold only through a broker-dealer and not by insurance agents.

The rule adds no consumer protection not already provided by state insurance regulation and would undermine many state initiatives concerning sales practices. I strongly feel that fixed index annuities are NOT securities (since there is NO RISK to the client), and should not be regulated by the SEC.

Sincerely,
Barney Chan