Subject: File No. S7-14-08
From: Ronnie M. Peret
Affiliation: Financial Services Representative for 40 years

November 3, 2008

I want to express my absolute opposition to Proposed Rule 151A for the following reasons: 1) As a former 35 year Registered Representative of NASD with a sterling record of compliance and service to my clients, I can tell you without hesitation, the Fixed Equity Indexed Annuity is no more an Equity Based "Security" product, than is a standard Universal Life Insurance Policy 2)The State Regulators are absolutely competent to regulate this product, just as they do with Life Insurance or Health Insurance and, 3) "Nationalizing" the regulation of so many different and varied products with all their differing, state mandated policy terms, riders, and provisions will be a regulatory nightmare for not only the SEC, but due to this new regulatory nightmare it will adversely affect consumers, agents, and Insurance Companies, ALL.

Please reconsider and cancel this grossly ill conceived and totally unnecessary proposal to regulate these products.

Thank you,

Ronnie M. Peret