Subject: File No. S7-13-08
From: Robert L. Bodack

July 23, 2008

The SEC has proposed "Rule 151A". Essentially, you want to make Fixed (Guaranteed) Index Annuities a Securities type product, that you can regulate, and thus, go from the State regulated Insurance Company distribution channels to a Federally regulated (SEC/NASD) Broker-Dealer distribution network, and at the same time, it will put all of us, who are NOT Securities licensed (and never wanted to sell Securities) OUT OF BUSINESS This is an unnecessary layer of Federal Securities regulation on top of, what has heretofor, always been a non-securities State regulated Insurance product. Finally, it's almost as if you are trying to "sneak this one in" due to the unusually short Comment Period. I am, and have been, a Life Health Insurance Agent here in Farmington Hills, Michigan, for over the last 30 years. I have NEVER had an Insurance complaint against me. I AM NOT SECURITIES licensed, so I do not sell Variable Life or Variable Annuities. I ONLY sell Fixed Life and Fixed Annuity products ("Fixed"...read Guaranteed products).
Sincerely respectfully,
Robert L. Bodack