Subject: Ruling 151A

October 30, 2008

After 22 years in the Life Insurance business I feel compelled to response the proposed rule 151A. It defies common sense that a product which has virtually no market-related downside risk should be considered a security in the same manner as mutual funds or variable products which the investor bears the risk for market losses.

It is appalling to me that this would even be considered, of the millions of dollars I have on deposit in Fixed Indexed Annuities everyone of these clients are sleeping well at night during this disastrous down turn in the Stock Market. Needless to say Fixed Indexed Annuities are Insurance Products not Securities! Not one penny has been lost and everyone of my clients have more today in their Fixed Indexed Annuities than invested, lets see someone at Market Risk say that today!

In regards to the very over exaggerated reports of wide spread abuse in this market by bias organizations such as Date Line NBC (for crying out loud). I feel the State Departments should handle these few bad agents and enforce the insurance regulations we already have. Again Annuities are Insurance Products not Securities that why the Guarantees in these products have protected my clients from market losses.

I urge the SEC to NOT pass this ruling and focus on the much, much larger abuses you have your hands full with now. Really, where was your oversight during the past years before the Securities industry turned this Country Upside Down. While my Fixed Indexed Annuity clients are sleeping well with Principal Guarantees and positive returns on their money because we are insuring their Money not investing it at risk!

George H Preacher, LUTCF, LTCIS