Subject: File No. S7-14-08
From: Eugene J Wittstock
Affiliation: Managing Partner, Jalbert Financial Group, LLC

September 2, 2008

I am in opposition to the Rule 151. If equity index annuities will become a registered product – I and thousands of other people in my situation will lose the only source of income they have. Many people have lost security registration and will not be able to re-associate with a broker-dealer even dough FINRA would consider them taking back.
Selling fixed products gives peace of mind to all of my clients who are risk averse. Registration means – only additional fees going to the broker dealer and other groups not directly responsible for the fiduciary relationship between annuity salesman and the client.
The individual states and the respective insurance companies have already implemented very strict monitoring mechanisms so their agents sell the products properly according to general rules used already by FINRA. For example, Midland National uses a set of specific questions identifying the appropriateness of annuity product in the selling process.