Subject: File No. S7-14-08
From: Steve Quinn

November 17, 2008

I am writing in protest against the possible ruling for SEC Ruling 151a. I've been in the investment and insurance business for well over a decade and still teach insurance CE classes approved by the State of Colorado.

Having done my own large amount of due diligence on index annuities, I don't see any way in the least that they would be considered securities. As anyone who truly has studied fixed index annuities can attest to, these are a form of fixed annuities. They can credit your interest in a different way (or the "regular", fixed annuity way), but offer all that securities do not: protection of your principal, guaranteed by the strength of the underlying insurance company. Securities of all kinds, by their nature, do not do this.

There is no one perfect investment or place to put your money, but fixed index annuities offer a truly safe place for one's principal with the guarded opportunity for quite decent interest growth. And the vast majority of these actually DO have a great amount of liquidity, if needed.

Please continue to keep index annuities under the auspices of the departments of insurance, where they belong. Thank you for your kind attention.