Subject: File No. S7-14-08
From: Kenneth R Mouille
Affiliation: 28 yr. Insurance Professional

November 12, 2008

As a 28 Yr. Insurance Professional I totally oppose the Rule 151 A The Securities licensed people are jealous and just want "a larger piece of the pie" , i.e. More Commission dollars. They are afraid of competition and would rather be able to prey on Seniors retirement income without Insurance Professionals offering a viable alternative ,i.e. Fixed Index Annuities. The security licensed people should be ordered to get Group 1 Licenses and Training by Insurance Professionals so they can be more informed. Securities people are good examples of why the Seniors Retirement Funds in the current market are at tremendous losses and most probably will not be able to recover. Rule 151 A is ill-conceived and to broad. It adds unnecessary layer of securities regulation to an Insurance product. Fixed Annuities, on the other hand, are Excellent with giving safety, guarantees, tax-deferrals, and flexibility. Fixed Annuities are already regulated by State Insurance Depts. and this should be enough. All in all, Proposed Rule 151 A, should be withdrawn and the SEC should let the State Insurance Depts. handle the job as they have been doing .
Thank You,
Ken Mouille