Subject: File No. S7-14-08
From: Jim Toddy
Affiliation: Financial Services (Series 7, 63 state insurance licensed)

July 30, 2008

Rule 151A should not be allowed to go forward. The SEC is trying to regulate a insurance product which falls outside of there duties to the securities industry.

Lets call a spade a spade, the SEC wants to regulate these products so that they can increase revenues to the organization, period.

I represent the greatest industry this country has (in my opinion) and as a independent I will always look to help protect and shield my clients assets from risk and Fixed Indexed Annuities are accomplishing that end.

Regards,

Jim Toddy