Subject: File No. S7-14-08
From: John F Ladgenski

September 2, 2008

I have been a licensed insurance agent for 33 years. Proposed rule 151A is in my estimation completely an overreach on the part of the SEC. Index annuities are already are already regulated by all the sate insurance departments and your proposed rule adds no consumer protection and would in fact undermine many state initiatives concerning sales practises.

I am very proud of the work I do in educating my clients on all aspects of the products I am able to offer them. The people who make up my clientele do not want any products that contain market risk. They do however, wish to try and obtain returns that compete very favorably with bank CD's. The index annuities offer those features to them.

Thank you for taking the time to read my comments.