Subject: File No. S7-14-08
From: John W O'Neil

November 17, 2008

Regarding File number S7-14-08. I oppose the proposed rule.

I have been a insurance agent only since 2004 so I feel not as seasoned as others in the industry. Although I believe it's not the length of time involved in the industry it's the quality of person you are.

There are individuals with securities licenses that inform you when and what to purchase although not when to sell. Or they tell you after the value of your investment has decreased a significant amount to hold on. I believe at that point in time you must or have a real good feeling that another stock will have a quicker and better potential to rebound than the current holding.

Over the past six to eight weeks I have spoken to clients of mine that valued my opinion in the index annuity market. Some didn't remember their valuable nest egg was protected against the down side until I refreshed their memory. They felt confident after our conversation they chose the correct vehicle to place their hard earned money.

Therefore I having been on both sides of the equation deem it would better to clean up the rascals in the industry not the industry. Index annuities are an excellent safety net for those that are especially entering their retirement years.

Regards,
John O'Neil