September 6, 2008
The proposed SEC rule 151a is wrong and should not be adopted. Fixed index annuities are not invested in the stock market and are guaranteed against loss of principal by the issuing life insurance company. Since there is no risk of principal loss to the consumer, it cannot be a "securities product" and should not be regulated as such. This product is adequately regulated by the various state insurance commissioners. This regulation seeks to impose federal oversight where it is not needed. I urge the commission to reject this proposed rule.