Subject: File No. S7-14-08
From: Donald E Reline, Jr
Affiliation: National Assoc of Ins and Financial Advisors (NAIFA)

July 11, 2008

I am a senior (70 years old)and have been in the insurance business 40+ years) I am writing to oppose rule 151A as I do not feel that this rule will benefit seniors at all. What it will do is require more regulation and additional expenses to be built into the products and make them less attractive to consumers. The propose rule will also reduce the number of agents who will be able to offer a product that is benefical to many savers. Index anuities meet the needs of the saving public. They are risk adverse saving vehicles, so a consumer can never lose their prinicipal, the principal is guaranteed and guarantee of interest credited. They are not high risk products where a consumer can lose their principal and even the earnings that they had accumulated. Just remember 2000-2003. The index annuity should stay under state insurance department rules. Index annuities provide underlying interest guarantees required by state law. Seniors (me included)need guarantees, not pie in the sky projections. When I purchase or sell Indexed annuities everyone has the guarantees that they will not lose their money, and expectation that they may earn a rate of interest that ties their growth to an index of their choosing or the fixed interest bucket or combination of them, money that cannot be earned again due to their age and employment situation.
Please reject rule 151A. Thank you for taking the time to read my comments. Don Reline