Subject: File No. S7-14-08
From: david b lennox

October 14, 2008

Rule 151 should be voted no on because plain and simple equity indexed annuities are not securities. They have minimum guarantees and no opportunity for losses due to market underperformance. It is, however, very important for the advisor to fully evaluate the clients financial position to determine the extent as to what portion of their portfolio an equity indexed annuity might fit into.