Subject: File No. S7-14-08
From: Craig R. Scott

November 17, 2008

Proposed rule 151A is ill-concieved. FIA products are heavily regulated by the insurance departments. Through NAIC, regulaters have worked hard to come up with appropriate suitability and disclosures. This work continues and should not be interrupted by the SEC's action. These FIA products give the client gaurantees, flexablity, and many other advantages.
This rule would add an unnecessary layer of securitey regulations to mthis product. Rule 151A would turn most FIA products as well as other fixed annuities into securites. This would be a slippery slope. It would also cause confusion over the differences between secuities and insurance.
With the recent market decline, it hightlights the value of an FIA. While millions have suffered great losses, there are also millions who have not lost a penny in their retirement plans through FIA's.
The rule defies common sense that a product which has virtually no market risk should be classified as a security in the same manner as a mutual fund or variable annuity.
FIA's give people a peace of mind that market fluctuations do not adversely affect their accounts values.