September 2, 2008
I would ask you for a time extension to reconsider the proposed rule 151A since it does not seem logical for The SEC to consider fixed index annuities as security products since they do not have market risk. The state Insurance departments are doing more than an adequate job in supervising these products and there should not Be an additional layer of regulation for these non-security products. To force insurance agents to become registered Reps in order to sell this fixed indexed annuity product is grossly unfair, unnecessary and illogical. It will be very Time-consuming, expensive and confusing. The rule would add no consumer protections not already provided by State insurance regulation and would in fact undermine many state initiatives concerning sales practices. I ask you to extend the comment period and I oppose this uncecessary rule. Thank you,
Russell A. Roeber, Spokane, wa. Insurance agent and registered representative.