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U.S. Securities and Exchange Commission

The following Letter Type N, or variations thereof, was submitted by individuals or entities.

Letter Type N:

RE: File No. S7-14-08
SEC Proposeed Rule 151- Under the Securities Act of 1933

Dear

This proposal, ( if adopted), suggests that lnsurance Companies issuing Fixed Idexed Annuities (FIA's), be required to comply with registration requirements that are currently used for securities, within one year. FIA's are Insurance Products, not securities.

The SEC publishedi heir proposal on June 26th of this year and has now extended the Comment Period for an additional 30 days to allow Insurance Industry representatives and Insurance Agents to evaluate and/or offer alternative methods of regulation. This continued push to change still drives a hasty call to action, considering the proposal surfaced some ten years after the SEC initially uncovered issues that, until now, have been shelved. FIA's have flourished in the Insurance industry over the past ten years, while under the carcful watch of Insurance Commissioners in every State. The State Insurance Cormissioner must be allowed to continue to regulate FIA's in order to perpetuate otherwise unprecedented financial stability that millions of policy holders have experienced while under State jurisdiction.

The FIA market has grown tremendously; largely because Insurance Companies have stepped up with contractual improvements for policyhoiders. Since inception, FIA products have been steadily fine-tuned for the benefit of Americans providing them access to products that guarantee, in writing, shorter surrender periods and lower surrender charges. In fact, millions of FIA policyholders have not lost one, single penny during the recent plunges in the stock market. Retirement savings plans for clients who have utilized FIA's continue to reap unsurpassed, solid, finamcial performance gains. Their hard earned nest eggs remain insulated from the perils of unpredictable markete exposure. Because no market-related downside-risk exists, Americans with FIA's should continue to be able to place their retirement monies in these vehicles without unnecessary intervention from the SEC.

FIA's are backed by minimum guarantees, rather than being subjected to the intense risks experienced in the stock market. The SEC is charged with the grave responsibility of regulating and protecting investors. I ask you to exercise a diligent effort, noting the failed efforts of the SEC as related to the recent decrease of financial stability across the United States. I also implore you to contact SEC Chairman: Mr. Christopher Cox immediately indicating that FIA's are Insurance Products, not securities.

While you are certainly aware ofthe fact that the passing of SEC Proposal 151 does not require Congressional intervention, I ask that you act on behalf of the Insurance industry on a State level. As it's most influential catalyst you have the power to bring to fruition, the right of Insurance Companiesto demonstrate the plight of FIA regulation in the near future, should SEC Proposal 151 move forward. Your efforts in this regard will clearly demonstrate a willingness to honor your responsibility on behalf of your constituency.

Thank you for your immediate attention to this matter!

 

 

http://www.sec.gov/comments/s7-14-08/s71408-2210


Modified: 10/24/2008