Subject: File No. S7-14-08
From: Martha S. Starcher
Affiliation: Licensed Insurance salesperson State of Florida

September 3, 2008

Sirs, The proposed rule which would require most fixed indexed annuities to be registered under federal securities laws. The proposed rule, 151A would serve no purpose but eliminate professional, educated insurance persons from the ability to expand their services to their clients and eliminate a souce of revenue vital to an insurance salesperson livelyhood. This bill does not offer any enhancement to the client that does not presently exist with the present insurance sales. This bill is just giving the opportunity to the brokerage firms expand their revenues, without offering an appreciable advancement in services. History has proved that many of the "variable" annuity sold only by the brokerage firms have been in many cases, been largly detrimental to the clients who have purchased them over the years. The fixed and indexed annuities have proven a far safer investement for the insurance client,seeking safety and growth of their hard earned monies, therefore the brokerage firms are now wanting to control that business and limit access to potential clients in order to control prices and take the potential revenue. All this to the detriment of the insurance sales force and companies that have worked long and hard to develop that product.
Please extend the comment period in order to fully study this proposal.

Sincerely,
Martha Starcher (Pattie)
Licensed Insurance Sales
State of Florida