Subject: File No. S7-14-08
From: Kenneth N. Horton
Affiliation: loan consultant / retirement planning

October 29, 2008

First of let me say that the "Fixed Index Annuities", FIA, are excellent product that give my clients and consumers guranatee's, flexability, tax deferral and many other adviantages. It's true that this product is not for everyone, but my sales of these products have given my clients and others a combination of guaranteed protection, and the opportunity to earn a higher rate of return than traditional annuities.

The SEC'S draft regulation of (rule 151A) adds an unnecassary layer of SEC regulation to an INSURANCE product. This rule would turn most FIA products- as well as some non indexed annuities into securities. This will have a far reaching effect on how these products will be sold. I believe it will cause confusion, between what is an insurance product vs a securities product.

I don't know who decided this would be a good idea... Its ill conceived, even by many SEC lawyers. I am told it does not have a judicial precedent... What are you thinking..?

Insurance product are heavily regulated by state insurance rules.. Another layer of regulation is not needed...

I am sure there are abuses in the marketing of the product, but that is MARKETING... not the product... The products peform very well... In this recent down ward turn of the market... where people lost millions of dollars... my clients did not loose anything... SAFE and SECURE... Lets let insurance products... be regulated by the insurnce industry... Not the SEC... it is not needed...

Thanks Ken Horton