Subject: File # S7-14-08

September 10, 2008

Our firm would like to support the request for extension for comments on Rule 151A.

The logic behind this request is that we have been marketing Equity Indexed Annuities (EIA's) since 1995 to our clients which consist of seniors over, (IRA's), age 55 and the Clergy market, ie; Ministers and employees of church organizations, (403b products).

We have had great success marketing these products for many reasons, to name a few:
1) Safety of principle
2) Tax deferred growth
3) State insurance guarantees
4) Ease of understanding by client when exlained properly by our agents
5) Following rules of the Suitability Reports for the clients providing comfort levels

The majority of our clients are within Clergy or Church-related positions. These folks do not always have a surplus of funds to draw from, and the amounts placed in the EIA's provide them with a way to fund their much-needed retirement program without worry of the market turndowns and subsequent losses. To force a rule such as proposed in 151A, would serve to not only confuse our clients, but would force many of them to shy away from a product that is an SEC regulated product, therefore subject to losses within the market, not to mention exhorbitant broker's fees on an ongoing basis. Most of all our clients are trying to get out of the Equity Market , so their retirement accounts will stop shrinking due to market losses, etc.

This action would also cause much more confusion in the paperwork and SEC compliance of small insignificant matters that would be required for us as agents.

Fixed Annuities are great products offering many advantages to clients, especially in down markets, and greatly increase costs to both clients and agents. We feel the regulation is being rushed to adoption and the general public should have input regarding their comfortability of the products. We further feel that the criticism of the EIA's, mostly coming from Registered Representatives that are not allowed to offer these products in many cases, is unjust, uninformed, and unfair.

The cost of the regulation to insurance companies, duplication of many efforts by these companies, and the general economic impact on the industry as a whole, does not merit further adoption study of the rule.

Respectfully submitted,

Jerry L. Peters, Sr - President
Julep Financial Services, Ltd.