November 17, 2008

Subject: File No. S7-14-08

Good Afternoon,

I am an insurance agent with 30+ years in the business holding a BBA in Risk Management & Insurance along with a MBA.

While no longer a primary thrust of my business I continue to write fixed annuities where appropriate. As an example my neighbor retired from our local school district two years ago and voiced concern about the stock market in which she was invested via her 403b variable annuity. We rolled her funds to an Allianz product, and as you can imagine considering the market, she now thinks I hung the moon.

I held a securities license for almost ten years, but when my BD insisted on me getting a Principals license I decided that the additional administrative burden would render this area of business not cost effective.

Proposed Rule 151A attempts to correct a problem which does not exist, and besides, state insurance departments already exercise oversight in this area.

Let's keep what little power and control states have away from the already over burdened and burdensome federal government and allow insurance agents to continue to offer this product without additional licensing requirements. I, for one, will stop offering fixed annuities should proposed Rule 151A be adopted - much to the detriment of current and future clients.

Vote no for its adoption.

Stephen J. Warrell
STRATEGIC BENEFITS GROUP