Subject: Opposition to Proposed SEC Ruling 151A

September 9, 2008

Recently, the United States Securities and Exchange Commission proposed a new Rule 151A that will define most indexed annuities as securities. I am writing to oppose this proposed regulation and I am asking for your support to keep the proposal from being enacted.

I am an employee of Asset Marketing Systems, an independent field marketing organization. We are here to provide support to insurance producers. Fixed index annuities have been recognized and affirmed as insurance products by every state commission. Sales are highly regulated by our state’s insurance commission and the insurance carriers. This ruling will require insurance agents to obtain a securities license to sell these insurance products. There are numerous agents that do not have a securities license. This will drastically hurt the industry and their employees like myself. Sales will also drop significantly.

Please take immediate action to oppose Rule 151A and support independent insurance professionals and their businesses.

Sincerely,

Virginia McCardell

Virginia McCardell
Engagement Specialist
Producer Progression Team
Asset Marketing Systems