Subject: File Number S7-14-08

September 4, 2008

Florence Harmon
Acting Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609

Florence Harmon:

I am writing to you as I am opposed to Rule 151A. I am a licensed insurance agent and a registered representative of a broker-dealer. I believe indexed annuities are properly regulated by my state's insurance department as an insurance company product, not as a security. While I am aware of the abuses that have taken place by people who mispresent these products in unsuitable sales situations and do not support these tactics, they are not sufficient reasons for the SEC to regulate them.

My professional organization, the National Association of Financial and Insurance Advisors, has had many years of experience working with the NAIC and I am convinced that NAIFA will support the NAIC's model regulations on annuity suitability and disclosure.

I urge the SEC to withdraw proposed Rule 151A. Thank you for your consideration of my position on this matter.

Sincerely,

Ron Staebell