Subject: File No. S7-14-08
From: Jeffrey Luckenbill, ChFC

October 21, 2008

I fully support Rule 151A. Several times a year I come across these products which are inappropriately placed and/or misrepresented to the client. There is often a lack of adequate disclosure and understanding on the client's part regarding performance/long-term "cost", withdrawal fees, taxation, etc. If these products want to be linked to securities indexes, then they should be regulated as secuities.

For disclosure, I am licenced to sell both fixed and variable annuities and securities.