November 15, 2008

Subject: 151-a s7-14-08

I would like to express my concerns about 151-a.

I have been working in financial services for over 36 years. I started with a major life insurance company as a Life & Disability agent and then added Casualty insurance, Securities and LTC insurance.

I was an agent for 5 years, a supervisor for 5 years, an Agency Manager for 12 years, and then returned back as an agent for 14 years. I started my own company 3 years ago because all the companies I worked for would not allow me to write Fixed Index Annuities along with all the other products. They wanted me to write Variable Annuities only. I need to be able to provide the right product for the right RISK AND NEEDS for my client!

Today, my clients are very happy I made the change because they have saved 100,000's of their hard earned dollars because they bought Fixed Index Annuities and Mutual Funds, Variable Annuities etc..

This new Fixed Annuity product allows our clients to enjoy the chance for higher returns without the down side risk. It is not the fix-all product for all their needs, but it allows options for them.

My previous manager said that we should not sell any fixed products to our clients because the low returns would hurt them in the long term. He was never taking into consideration the losses they may incur. I can only imagine how much money his agency clients have loss during this bear market? I know that my clients had that choice to buy Fixed Index Annuities and now they are telling me how happy they are because they did not lose as much of their hard earned money during this bear market!!

By regulating this Fixed Annuity product you will reduce the chance for clients to even hear about this product through a broker. The companies that represent brokers forbid them to sell this new product.

Full disclosure and getting all the facts concerning our clients needs and risks is what is needed today.

PLEASE!,understand that millions of people need to have access to low risk products as well as higher risk so they can take the right risk for the return. IF YOU ONLY ALLOW BROKERS TO SELL THESE PRODUCTS (WHICH ARE REPRESENTED BY THE COMPANIES THAT DO NOT WANT THEM TO SELL THIS FIXED ANNUITY) WHAT WILL HAPPEN TO THE PUBLIC DURING THE BEAR MARKETS????

PLEASE LET THE PUBLIC HAVE A CHOICE. THEY SHOULD NOT ONLY HAVE THE CHOICE OF HIGH RISK OR BANK ACCOUNTS.(CD'S)

I know all clients need choices!! If ONLY BROKERS CAN WRITE THIS PRODUCT WHAT CHOICE WILL THE PUBLIC HAVE??????????????????????????

I hope you make the right choice for the public (WHICH ARE YOUR CLIENTS TOO).

Note: This new product is a change to the Annuity industry as Universal Life insurance was to the Life Insurance industry, in the 1970s.

Thank you for your consideration,

Randel D. Stephenson

Randel D. Stephenson, LUTCF
Registered Representative