Subject: File Number S7-14-08

September 8, 2008

I am a Pennsylvania Licensed Insurance Professional for 20 years. I do not support the adoption of rule 151A. I believe that Index Annuities should continue to be treated as an insurance product, & not regulated by the SEC. Properly structured indexed annuities do not share the same risk associated with stocks & mutual funds. I do support NAIFA's recommendation that a state regulatory body be designated to develop standards for indexed annuity product design, so that inappropriate product's would not reach the market place. Furthermore my very own 87 year old mother owns an index annuity as a safe, sound investment without risk of principle. Sincerely,
Scott S. Wise