Subject: File No. S7-14-08
From: Melvin D Hogan

September 9, 2008

I am a constituent in the State of Texas. My livelihood and business as a licensed, independent insurance agent may be greatly impacted by the proposed rule 151A recently published by the Securities and Exchange Commission. 151A focuses on fixed index annuties, which are fixed annuities already regulated by the state department of insurance and sold by licensed insurance agents such as myself. Through this proposed rule,the SEC is seeking to require that all "fixed index annuties" become "registed products" sold only through a broker-dealer and not by insurance agents. For the consumer, the guarantees in fixed index annuities come at a price, but the risk factors in these annuities are practically nil, there is no risk of principal or earned interest during the interest crediting period, and their early surrender charges are dwarfed to Tom Thumb comparisons with all the risk factors of "registered products" sold by broker-dealers. It should be considered by the SEC that this rule is superfluous to consumers in that it adds no "consumer protections" not already provided by state innsurance regulation, and will in fact, undermine many state initiatives concerning sales practices. There should be an extension of the comment period for rule 151A in weighing out this questionably unnecessary rule.