Subject: File No. S7-14-08
From: Frederick M. Woolley, CFP

September 3, 2008

Please reconsider the proposal for SEC regulation of fixed index annuities and allow the states to continue their oversight.

Fixed index annuities are a unique vehicle that offer the potential for growth while providing sufficient protection in a declining stock market. This allows well informed clients the ability to have peace of mind regarding a portion of their investments that are not exposed to be volatility of the market.

Rule 151A adds an additional unnecessary layer of regulation to an already highly regulated product.