Subject: File No. S7-14-08
From: Thomas R Osborne

September 3, 2008

File No. S7-14-08 -As legal experts review SEC's proposed Rule 151A, I continue to aggressively oppose the proposed rule and strongly believe that fixed index annuities are not securities and should not be regulated by the SEC. Midland National is committed to efforts that promote and ensure that fixed index annuities are marketed and sold with proper disclosures and in conformance with all suitability guidelines and requirements. I support the current regulation of these products by the insurance departments of each state.

I would suggest that the SEC Rule 151A is more about limiting competition. I am licensed by the State of Michigan to sell Health and Life products and enjoy helping people achieve safety and maintain an income stream without the Market Risk by having down-side protection.