Subject: Opposing Proposed Rule 151A

September 6, 2008

I am a Life Insurance Agent in California and I wish to comment about Proposed Rule 151-A.

• Fixed Indexed Annuities are very good products and offer many benefits to consumers, including protection against market risk and tax deferral.
• The recent downturn in the market has not effected those holding FIAs. It highlights their value.
• I do not believe it makes sense to consider FIAs a security, because it is not a product that is subject to downside market risk.
• Proposed Rule 151A would create an unnecessary layer of regulations causing confusion among consumers.
• This rule is being rushed to adoption with just a short comment period being allowed. The comment period should be extended.
• Criticism of FIAs have been exaggerated. State regulators have worked hard to put in place logical controls.
• Market abuses have been largely corrected by the State Insurance Departments.
• Requring Insurance Agents to become Registered Representatives is unfair, very expensive and a time-consuming process.

I hope you will consider these comments. Thank you.

Leonard W. Fox
Bill Fox Financial and Insurance Services