Subject: File No. S7-14-08
From: Robert G Wheeler, CLU, ChFC
Affiliation: Owner/The Robert G. Wheeler Agency

September 6, 2008

I strongly oppose Proposed Rule 151A. Rule 151A would create another layer of unnecessary regulation. This would cause confusion for the consumer, as these products are already well regulated by each state's insurance department. These products have may advantages for the consumer and should remain under the supervision of each state insurance department, and not the SEC. Since these are fixed indexed annuity contracts, it does not seem necessary for annuities that have no market related downside risk for the consumer, to be treated like securities. I urge you not to create another level of control, when it is not necessary to do so.

Thank you for your attention to this message.