Subject: File No. S7-14-08
From: Marcy Nunn
Affiliation: President, MKN Financial Group

October 22, 2008

All fixed annuities, including equity indexed annuities, are insurance products. They are not investments nor are they securities subject to market risk. To allow only those with security licenses to sell them simply doesn't make sense. These products are tailored for the risk averse. It is extremely important that these products remain to be discussed with the public as an alternative not only to other higher risk policies and but also to the higher fees of variable annuities and securities. The large majority of fixed annuities are sold by insurance agents and not registered reps. There is no indication that this would change if this law were passed. It is very important to keep these products available to the public, especially considering the current state of the economy. Please vote no on Proposed Rule 151A.