Subject: File No. S7-14-08
From: Robert J Speed
Affiliation: licensed independent insurance agent, FIC, MPA

October 7, 2008

File No. S7-14-08 -- Proposed Rule 151A
I have previously submitted comments opposing this proposed rule.

Events subsequent to my previous comments, specifically the international financial meltdown that has occurred partly caused by companies under the regulatory oversight of the Securities Exchange Commission, only further underscore reasons to oppose SEC oversight of indexed annuities.

It has become readily apparent that the SEC either does not have the resources to regulate financial products, services and institutions already under its perview, or does not use the those resources proficiently.

The idea that the SEC could somehow conduct better oversight than state insurance departments in taking on a redundant regulatory role involving indexed annuities -- considering the SEC's obvious problems dealing with its regulatory, enforcement, and oversight responsibilities over its current portfolio -- is patently ludicrous on its face.

Indexed annuity products are fixed annuities, and like all fixed annuity products have a base value guaranteed contractually by the issuing insurance companies generally have a stop-loss provision backed by the full faith and credit if the issuing insurers themselves and are further backstopped by state regulatory protection in event of financial failure of any individual company.

During the recent debacle involving SEC-regulated financial institutions (and institutions regulated by other federal agencies), indexed annuity owners did not lose one penny of value under existing state jurisdiction.

The SEC needs to clean its own house and better manage the responsibilities the agency already has before ever considering taking on new responsibilities when there is no emergent reason to do so and little faith that the SEC could do a better job than is currently done well by the various states.