Subject: File No. S7-14-08
From: Melissa Johnson

September 9, 2008

To whom it may concern:

I strongly oppose the SEC proposed rule 151A. This would, in effect, define most indexed annuities as securities.

Two years ago as the Real Estate Industry continued to spiral out of control and housing prices were plummeting, I lost my 9 year career as an Escrow Officer. Despite several warning indicators that the fall of the Real Estate market would dramatically affect the U.S. Economy nobody in power did anything to help protect the consumers, the Mortgage Industry, Title Escrow Industry, and property values. This had a catastrophic effect on thousands of people who made their living in this line of business. After spending the last 2 years re-building my life and making a new career for myself, you now want to propose a rule that would make FMO's obsolete and once again leave me without a job all so you can make more money by getting a piece of the FIA market and the profits they generate. It's interesting how governing agencies will step in when they feel like it – but that it doesn't usually have a positive effect on those who are directly affected by your poor decisions.

I find it very concerning that you are attempting to slam this new ruling into place and hope that nobody is looking while you try to get in on the FIA action. Unfortunately if this passes, it affects FIAs and then it will then affect UL products and then ultimately Life Insurance Products. Convenient you dont mention those facts when you attempt to make your case and say that you are "looking out for the consumer" since the Insurance Regulators "have not" which as we both know a complete fabrication. Indexed annuity sales are regulated more than adequately by the state insurance commissions, the SECs proposal merely adds to governmental bureaucracy without providing consumers with additional protection. Suitability rules in both the insurance industry and the securities industry mirror each other. Moreover, since dispute resolutions within the securities industry take much longer, are more complex and are much more costly for the consumer than those overseen by my Department of Insurance, what is proposed will substantially hurt consumers rather than help them.

In effect your proposed rule is simply your bid to make more money. You should be more concerned with how your rule is going to negatively effect those its supposed to protect, the consumers and those who make their living trying to help those who want FIAs, and Life Insurance. While SEC employees might still have a job if this rule goes into effect, I more than likely will not.

Sincerely,

Melissa Johnson