Subject: File No. S7-14-08
From: Eugene W Draper, Jr.
Affiliation: Independent Insurance agent

October 28, 2008

10/28/2008

I am respectfully requesting that you join Representatives Meeks (D-NY), Price (R-GA) and Pryce (R-OH) in their opposition to the SEC's proposed rule 151a. If adopted, Rule 151a would adversely impact my business along with thousands of independent insurance agents throughout the nation.

The rule is seeking to re-characterize a fixed indexed annuity (FIA) as a security. An FIA is a savings product designed to protect not only principal but also any past interest credits. Adopting this rule will expose consumers again to market risk and remove important state regulated safeguards. We need more insured savings and financial instruments in today's marketplace, not more products that expose people to risk.

Again thank you for your attention to this important issue and I hope to have your support.

Sincerely,


Eugene W. Draper, JR

(Attached File #1: s71408-2247.pdf)