Subject: File No. S7-14-08
From: Bonita L Williams, CLTC

November 17, 2008

RE: File No. S7-14-08 / Proposed Rule 151-A

To Whom It May Concern:

As a member of NAIFA, I oppose the Proposed Rule 151-A.
This proposal is not showing any empirical evidence that supports the Commission's claim that the so-called widespread abuses in selling fixed indexed annuities exists.
As an independent agent, I will not make fixed indexed annuities available to my clients or prospects IF these products become registered as securities.
The appeal of indexed annuities is that they are NOT securities and are NOT subject to risk of loss from marketing activity. In light of the current economic fluctuations, I cannot understand WHY the Commission would choose to support to implement such a ruling.
Therefore, I would appreciate if you would reconsider your position and decline to implement the Proposed Rule 151-A.