Subject: File No. S7-14-08

September 9, 2008

Dear sirs,

On June 25, 2008, the United States Securities and Exchange Commission proposed Rule 151A. The intent of this rule is to define most indexed annuities as securities. I am writing to oppose this proposed rule and to ask for your support in this matter.

Although I am not a licensed insurance professional, I have been employed for almost four years by a field marketing organization that assists these professionals in helping to grow their businesses. If this rule were to go into affect, it will require these insurance agents selling indexed annuities to obtain additional securities licensing to sell the same products. It is my understanding that these products are all ready highly regulated by our state insurance commission. Enacting this rule would then appear to be redundant, costly, and unnecessary and will not provide consumers with any better protection.

The enactment of this rule would severely affect my organization. It would cost agents considerable time and money to obtain additional securities licenses. Many agents may choose not to get the necessary licenses, thus denying them of a source of revenue. Our revenues are directly tied to agent’s sales. If the agents decide not to continue selling indexed annuities due to this rule, then we could lose many agents, which could severely reduce our revenue stream. Reduced revenues could lead to a loss of jobs.

I am asking for your support in opposing Rule 151A. The rule could severely affect the livelihood of independent insurance professionals and their businesses. It is redundant and costly to these agents and field marketing organizations supporting them.

Sincerely,

Barry W. Meisen
Controller
Asset Marketing Systems Insurance Services, LLC