Subject: File No. S7-14-08
From: Larry J Moskat
Affiliation: CERTIFIED FINANCIAL PLANNER (tm)

October 20, 2008

Dear SEC:

Re proposed rule 151A...

Fixed Indexed annuities are insurance products. In some cases they have been sold incorrectly and unsuitably to consumers...as have securities in the past. But oversight, heightened suitability evaluations and training are what is required to move toward a better landscape for use of these products. The regulatory environment already in place can and should continue to make changes to accomplish this. The redesignation of these products to securities will not change the above requirements.

Can you tell me anyone who, in this financial meltdown, has lost money in these insured products? I know of no one. I know many who have lost money in securities.

Let's focus on oversight within the structure we already have. This measure is unnecessary and unwaranted. Thank you.