Subject: File No. S7-14-08
From: JoAnn Regan

September 8, 2008

September 8, 2008

Securities and Exchange Commission:

I oppose the SEC's proposed rule regarding Indexed Annuities. My opposition is based on the following:

1. State insurance departments are doing a good job of regulating the products and insurance agents. In recent years there has been increased suitability and disclosure requirements for Fixed Indexed Annuities. As in any industry there are sales people who have and/or will use abusive sales practices and the insurance departments are perfectly capable of handling the complaints in a timely and straight forward manner.

2. Fixed Indexed Annuities are not a security. There is no market downside risk and a minimum guarantee. Trying to put Fixed Indexed Annuities in the same category as stocks or mutual funds which do have investment risk is absurd.

3. A large part of the SEC's scrutiny involves abusive sales practices involving seniors. I have worked with many seniors and their primary reason for having a portion of their funds in an indexed annuity is wanting to protect it from market risk and/or loss. Seniors, in particular, are looking for alternatives to securities and a product such as the Fixed Indexed Annuity can be an excellent alternative. Educating the client on the pros and cons of the Fixed Indexed Annuity are part of my job, which I the agent, the participating insurance company and the State Insurance Department take seriously.

4. I believe the SEC is being heavily influenced by FINRA and is trying to exercise control over a product that is safe for consumers. Turning over the sales control of Fixed Indexed Annuities to broker dealers would just promote their own self interests and not those of the American public.

In conclusion, please reject proposed rule 151a for the benefit of millions of Americans desiring a safe and guaranteed alternative for their money, for all the small businesses and insurance agents who will suffer a negative impact if it is adopted, and for the purchasers of Fixed Indexed Annuities who need a local regulatory authority to resolve their complaints in a timely manner.

Thank you,

JoAnn Regan