Subject: File No. S7-16-08
From: Gary Crystal

September 11, 2008

I oppose the adoption of the proposed SEC Rule 151A.

I am a professional California Life Insurance agent with twenty years of experience working with seniors and those nearing retirement. I am as passionate about my business as any prominent and well respected Doctor or Attorney. In order to best serve my clients needs, I regularly attend educational classes and seminars on retirement planning, finance and estate planning and annuities well above and beyond what is required for my continuing education requirements.

I have clients who have regularly lost money with variable annuities as a result of high fees and market volatility. They have also been told to dollar cost average into the market with stocks such as Bear Sterns, Lehman Brothers, Fannie Mae, Freddie Mac and other sound stocks by stock brokers who are regulated by the SEC. Only after they have lost a substantial part of their nest egg are they churned and burned again.

Fixed index annuities do not share characteristics with securities. Instead, index annuities offer important protections that securities do not. Two important features are the guarantee of premiums paid and of interest credited.

My clients however, have never lost a dime. They own Traditional and Fixed Index Annuities. And I believe it would be a catastrophic mistake and a detriment to seniors if Fixed Indexed Annuities were under the control of the SEC. Seniors would pay a ultimate sacrifice.

Gary Crystal