November 18, 2008

Subject: Comments on Proposed Rule 151A s7-14-08

I must state my opposition to your proposed rule 151A, File # S7-14-07. Annuities, including Index Annuities are NOT "Securities" as described in the Securities and Exchanges Act of 1933. They are NOT publicly traded on ANY market, and involve NO INVESTMENT RISK! They are regulated by the states' insurance regulators. I hold Series 7, 63, 65, and 24, and feel very strongly that any attempt to limit availability of these products by requiring that they be offered through broker/dealers is NOT in the public interest! Are there horor stories out there? Of course there are! Just as there are horror stories concerning unscrupulous stockbrokers! Your responsibility is to police securieites slaesmen. Policing insurance salesmen is the responsibility of the states! Frankly, I have seen a tremendous tightening of compliance procedures since this proposed rulemaking came into place. The insurance companies are cleaning up their salemen's sales practices, and providing better education about these products. For that, I thank you; it was long overdue. Onetheless, it does not alter the fact that these products are contracts between an individual or entity, NOT securities. I hope you will drop this redundant and needless rule!

Sincerely,

Kris B. Lloyd, Sr.