Subject: File No. S7-14-08
From: J. K. Johnosn
Affiliation: Agent

November 5, 2008

Rule 151A is an ill conceived and misinformed plan.
Indexed annuities are interest paying products, not equity ownership. The fact that they pay an interest rate tied to an index does not make them a security. The plain fact that in each index annuity contract is that there is no down side, no loss of principal.
Anyone in a 401k, mutual fund, or equity stock have recently experienced what no annuity owner has ever experienced, loss of value.
Any problem that a contract/policy holder has experienced with annuity products (usually surrender charges that they did not understand or were not aware) are agent and/or communication problems. To believe that the SEC, that cannot adequately control what it already has perview over, can handle more responsibility and handle it better than 50 insurance commisioners who already have oversight systems in place is a fantasy.