Subject: File No. S7-14-08
From: Eric R Heckman, CFP
Affiliation: CEO

September 9, 2008

I fully Disagree with this proposed rule 151a. I too want to make sure consumers are protected against misleading sales tactics. However, the NAIC and insurance companies have taken huge steps to already impose new restrictions to ensure that consumers know what they are getting and to make sure it suits their situation.

Most of my clients want the safety of a fixed account but want to have the chance to earn higher than the historic low interest rates that are paid on fixed interest. They also want the opportunity to lock in the interest and not lose it in the future. They know they are not in the market and they know they are giving up potential for that protection. There are a lot of people who are dissatisfied with the stock market losses they have incurred but my clients thank me for protecting their money in a Fixed Index Annuity. No one has ever felt bad about their money being protected.

Current clients will suffer and future clients may have a lot less options due to this rule. I have seen costs at $850 million and that will come out of the returns of the consumer. So please let the insurance regulators continue to enforce their increased consumer protections but don't confuse consumers by telling them this is a product where your principal and earnings are at risk which is not true.