Subject: File No. S7-14-08
From: Lynda Jacquot-Imberi
Affiliation:

September 4, 2008

I am a licensed insurance professional for over 25 years. I am opposed to Rule 151A which would classify indexed annuities as securities. I believe they are correctly classified as a fixed index product.

I belong to NAIFA and we are committed to keeping our business ethical and we work hard to educate our professionals in this regard to see that all are presented with proper disclosures and legal materials.

I ask that you withdraw proposed Rule 151A and continue to allow the states regulatory structure to handle this.

Lynda Jacquot-Imberi