Subject: File No. S7-14-08
From: Mort S. Walton, Jr.
Affiliation: FL and AL Licensed Independent Life and Health Agent

November 17, 2008

I hereby submit comments in opposition of
the proposed rule 151A, and hereby reference the "File Number S7-14-08. I hope that I speak for all when I say that it is amazing after all these years of avid trust establishment among our fellow agents, our industry as a whole, and the trust we have maintained with our clients throughout our history, that this question has even arisen. Honestly, the amount of education, initial and continuing education required at present, to maintain an adequate understanding of the changing laws and product lines in the Life and Health Industry, let alone to remain legal, is stagering. Yet, the Life Insurance Industry with the help, guidance and perseverance of the individual State governments, and our body of Licensed reps as a whole has maintained and policed itself with incredible integrity for almost a century. We have held ourselves accountable, and we have carefully protected the interests of the many we serve. And interestingly we have a much better reputation than the SEC regulated industries and their products. Just ask the average buyer of any security or mutual fund what, or how little they understand about what they have just purchased. It is clear to me, that the motive here is strictly monetary, and not to improve the situation as it exists. I am open to discussion and explanation of my beliefs, but I clearly believe it is an abomination to consider putting control of Index Annuities anywhere other than under their current management. Sincerely,
MORT S. WALTON, Jr.
Independent Life and Health Agent for more than 20 years