Subject: S7-14-08

October 20, 2008

Dear Secretary,
Although there are several issues in the proposed regulation 151A that I could comment I will limit this email to one that effects only non-securities licensed older insurance producers. I am a 69 year old unaffiliated producer with no intention to retire although I have cut back my normal work week to around 40 to 45 hours. I have been licensed as an insurance producer since 1961 and currently hold resident and non-resident status in approximately 20 states. I have served on many association boards including The American Society of Financial Services, Life underwriters, The Million Dollar Round Table including "Top of the Table" and also the International Forum. I have served on several Life Insurance Company Agent Advisory Boards. I am proud to state that in my 50 years serving my clients that I have not had any complaints filed or actions imposed by any insurance department. Frankly I do not need government interference to know what is right or wrong. I apologize for the above litany, this background is intended as an introduction as someone with a deep knowledge of the industry and not intended for self promotion.

I voluntarily surrendered my Securities License many years ago because I thought I would better serve my clients as a specialist.
Now to my question: Considering that I have no intention to re-acquire a Securities License and further considering that Equity Index Annuities are an important part of my practice I view attempts to label this insurance product as a securities product as government interference and a threat to my ability to earn a living. In closing I would add that I have been fortunate and I have been financially rewarded for my hard work and dedication to the welfare of my clients. In the event this regulation was to finally come to fruition I would surely be a willing participant to litigation. Please reconsider this attempt at over regulation.

Sincerely

E. Dominic Firmani CLU, ChFC, CPC, QPA