Subject: File No. S7-14-08
From: William P Neurauter
Affiliation: Independent Insurance Agent

October 29, 2008

151A focuses on fixed index annuities, which are fixed annuities regulated by the state departments of insurance and sold by licensed insurance agents like myself.

This rule adds no consumer protection not already provided by state insurance regulation and would in fact undermine many state initiatives concerning sales practices.

The Illinois Department of Insurance requires more certification annually then the securities industy does of Registred Representatives.

Thank you for your consideration.