Subject: File No. S7-14-08
From: Kim L Cowdell
Affiliation: CLU, ChFC, CFP, LUTCF

July 14, 2008

This rule 151a proposed by the SEC is WRONG
Fixed annuities are just that They are not a security and should not be treated as such
They have guarantees and people can not loose money if held to maturity.
State guarantee funds are much better equipped to handle any type of insurance concerns in behalf of the public than the Feds.
I've been in the insurance industry for more than 32 years and have seen many proposals in my day, but this one has so many errors and inaccuracies that it's a travesty that they didn't have a few professionals that have been in the business a while, give some needed honest input.

If you need someone else on your task force please seek good competent advice and input from those in the know, who have their professional designations. ie CLU, ChFC, CFP etc.