Subject: File No. S7-14-08
From: Melvin Howard
Affiliation: Licensed Insurance Agent,

October 24, 2008

REgarding Indexed Annuities being treated as a security.
#1 The client has no chance to loose value as there is a guaranteed interest rate as part of the product.
#2 Fewer people would be served because the annuities could not be sold by anyone without a securities license.
#3 A special license or class could be required to sell these annuities. I was required to pass a class before I was allowed to sell, when these Annuities first became available.
#4 Do the brokerage houses see a loss of revenue since they don't control these products.

I am against Proposed Rule 151A