Subject: File No. S7-14-08
From: William J. Harbin
Affiliation: Valuteachers

October 25, 2008

I need a thorough explanation of the reasoning behind SEC
rule 151A, and what it will bring to the American people.
Equity Index Annuities have allowed many Americans to save
safely and without worry about their retirement. The client's State of residence has a Licence Commissioner who
approves companies and policies before business can be done
in their state. Agents have to evaluate clients in the same manner for both Life Insurance and Annuities, and with the client determine if the product is suitable for the client. Again state laws govern both Insurance Products and with Strict Guidelines for all products. After
many years of oversight and quality work by State Insurance Commissioners will rule 151A improve tis business. What rule 151A will do is remove thousands of agents from payrolls and remove a retirement safety net they give their clients. Broker Dealers will also have a monopoly and make the process expensive and more
complicated with less clarity. This will not only drive cost up, but reduce the personal contact agents have with American Families. Millions of Americans do not trust Broker Dealers with good reason.Equity Index Annuities are a quality product that benefit the client.
What is the reason for rule 151A. I submit it is to get rid of competition, with no reguard for the American Consumer.