Subject: I oppose proposed rule 151A

September 2, 2008

To Whom it may Concern:

I am in opposition to your proposed rule 151A because indexed annuities are NOT securities and have no need of SEC regulation. They are insurance products and the fixed indexed annuities that I and many others represent have no risk of loss to the owner as stocks and mutual funds do. Please do not regulate these INSURANCE products!

Larry Souza