Subject: File No. S7-14-08
From: Robert J DAlessandro

September 6, 2008

I completely disagree with proposed rule 151A. FIAs are completely misunderstood. Focus has been on abuses in the marketing and sales and not on the value they provide consumers. FIAs are valuable products in filling an important financial need for many Americans to participate in the market without the risk involved with other products. I personally have FIA's myself because I want to participate in the market without any risk on my part. I know that the insurance carrier is assuming mortality risk, credit risk and interest risk. If you wouldn't call that a fixed insurance product, I don't know what is. I live in the state of PA which has one of the best and toughest insurance commissions that look out for the consumer. The NAIC has adopted a suitabliity model and disclosure regulations that are applicable to FIAs. I am an independent insurance agent and have been selling FIAs since 2000 without one consumer complaint or any of them losing a dime, in fact they thank me.