Subject: File No. S7-14-08
From: Nate L Clark
Affiliation: President, Financial Velocity Concepts

October 29, 2008

I oppose Rule 151A. Fixed Indexed Annuities are obviously fixed insurance products that can not lose value due to a market loss. A marketable security can lose value. It is very clear that FIA's are in no way securities. This rule was introduced with very poor judgement.

Nate Clark,

Inestment Advisor Representative
Resource Horizons Group

President
Financial Velocity Concepts