Subject: File No. S7-14-08
From: Joseph Elison

September 5, 2008

To Whom It May Concern:

I appreciate the service the SEC provides for the financial services industry and the American consumer. I have been in the financial services business for 16 years and I am securities licensed. I feel very strongly that the proposed ruling 151A oversteps the jurisdiction of the SEC. Indexed Annuities are clearly a fixed annuity product and should be under the jurisdiction of the state insurance departments. Of course I can still offer the indexed annuities to my clients even if your proposal wins, however that does not negate the fact that it is still a fixed annuity product. I feel the proposal needs to be dropped.

Joseph Elison