Subject: File No. S7-14-08
From: JOLEEN K MISEK

July 30, 2008

I oppose the adoption of proposed rule 151A by the SEC for a number of reasons that include:

1. Market Risk. The design of fixed index annuities specifically allows individuals to avoid investment risk unlike securities products. Instead, the guarantees in an index annuity are similar to those in a traditional declared rate fixed annuity.

2. Risk and Rewards. Consumers who purchase Fixed Indexed Annuities do NOT assume any of the same risks and rewards that investors assume when investing in mutual funds, variable annuities and other securities.

3. Disclosure and Complaint Resolution. If the rule is adopted, consumers will lose a far superior complaint resolution process that include:
--Products and sales materials are reviewed locally by the insurance departments.
--Companies and agents must provide a written response within 10 business days of an insurance department inquiry and complaints are routinely resolved in 30 days.
--Purchasers can meet personally with a department of insurance representative to help them resolve any complaint.

4. Commissions. Commissions earned by insurance agents over the length of index annuities are often far less than those of an investment advisor or fund manager. In addition, these same commission percentages are paid through the Broker Dealer channel of distribution.

5. Judicial Precedent. In previous court cases judges have ruled that annuities, including index annuities were not securities because the products are subject to the approval of insurance commissioners, they offer minimum returns regardless of the performance of an index and that funds were not kept in a separate account.

6. Competition. The effect of the new rule, if adopted, would be to lessen competition, increase costs for consumers and reduce the availability of valuable products.

Please reject the proposed rule for the benefit of consumers who need a safe and guaranteed option for their savings, for the small business insurance professionals whose practices will be harmed by its adoption and for the purchasers of fixed index annuities currently served effectively by focused local insurance departments who are able to rapidly resolve any complaints.