November 16, 2008

Subject: File No. S7-14-08 Proposed rule 151A

I AM OPPOSED TO proposed rule 151A. I am a CLU and member of NAFA. I have been a licensed insurance producer since 1963. I was a Registered Rep with NASD (now FINRA) for over 30 yrs. I have written hundreds if not thousands of fixed & variable annuities both qualified & nonqualified as well as sold many mutual funds. since approx 2000 I have written many many fixed indexed annuities. What a God send FIA'S have been for my clients. I have had SEVERAL clients call during the recent economic crises to express their DELITE that their Fixed Indexed Annuities have NOT DECREASED in value 1 cent!! In fact they were delited that they had moved part of their $$$ to the FIA's especially in view of the losses they are seeing in "securities" (stocks/ bonds/ mutual funds/ variable annuities ect) they are invested in. I am a self employeed small bussines owner, as such the proposed rule 151A would reck havac with my bussiness as well as 10,000's of others. The proposed rule is not supported by ANY real evidence of "wide spread" abuses of selling FIA'S. In fact I think if you do proper research it will show more problems in sales of SEC Registered products than FIA'S. The 50 States do a fine job of regulating & negating any big abuses of insurance products - including FIA'S!! Rule 151A as proposed would restrict public access to the number of qualified agents selling FIA's compared to ones available currently. It would act as a detriment to the public good. The appeal of FIA'S & other fixed annuities is that they are NOT seurities subject to decreases & risk of loss of money due to the market. I can think of many of my clients that had taken there $$ out of risk investments because they could not afford nor bear knowing they could lose more $$ & were thrilled to learn about Fixed Indexed Annuities, they put from $5000 to $500,000 of thier $$ in to them because they wanted the Gauratees & they under stood the pros & cons of FIA'S. They needed the protection FIA'S provide to have a more seren & safe peaceful retirement at least with that amount of their nest egg. FIA'S are not for everyone & not for all of someones $$. FIXED INDEXED ANNUITIES are an insurance product -they are & should be regulated as they are by the states not by SEC/FINRA. The only ones to gain by SEC/FINRA involvment would be Broker/Dealers & fees they pay. It would also increase costs in FIA'S witch decrease their value to my clients. OH by the way the Dateline show was like all too many "news" pieces- it is more about selling their air time to advertisers than the whole truth of their subjectmatter! I have never yet & pray I never will have a complaint filed against me. I also tell my clients the WHOLE story the good & bad/ the pros 5 the cons.