Subject: File No. S7-14-08
From: Nicholas Salerno, Jr.

November 17, 2008

I oppose SEC ruling 151a and the push by some to have the Fixed Indexed Annuity policies regulated by the SEC and thereby require agents who wish to sell them to become securities licenced.
First, the FIA is not a "security." It is an insurance product with guarantees and safety not found in security related investments.
Second, the licensed agents who offer them here in California, as well as other states that i am aware of, are required to complete an 8 hour annuity-specific education course, as well as meeting on-going CE requirements each license period.
Third, I have met over a thousand agents, like myself, who have traveled all over the country in order to gain additional anniuty-specific and related educational training so that we may understand, and apply, the high ethical standards to our practices and thereby help the people we serve accordingly.
However, if you feel that insurance agents should have additional specific training in order to handle the FIA sale better, then why don't you simply implement such training through the current system which is over-seen by the various state insurance departments.
Last, many advisors/agents, like myself, work with people who are in their retirement years, and we do not have a desire to sell or recommend securities that put our clients' money at risk.
Please leave these products under the supervision and regulation of the state departments/divisions of insurance.
Thank you for taking the time to review my comments.
Nick Salerno, Jr.
760-439-2213