Subject: File No. S7-14-08
From: Jeffrey Burden
Affiliation: Insurance Agent

August 1, 2008

I oppose the adoption of the proposed SEC Rule 151A.
Fixed index annuities do not share characteristics with securities. Instead, index annuities offer important protections that securities do not. Two important features are the guarantee of premiums paid and of interest credited.
There is a large and growing segment of U.S. consumers who feel annuities including index annuities meet their long-term savings needs because of those guarantees.
Although there have been a few instances of questionable sales tactics, individual states and the NAIC have addressed them in an effective manner. It is also true that the incidence of complaints for index annuities is actually far less as a percentage of transactions than it is for variable annuities. The proper supervision needed for traditional fixed annuities, indexed annuities, and life insurance is currently being performed effectively according to state insurance department rules.
The net effect of the proposed rule will not be a benefit to American savers, but will reduce the number of agents who will be able to offer a product that is beneficial to many savers, thus reducing the opportunity for consumers to purchase it. It will also create unneeded additional expenses for filing, regulation, and supervision, the cost which will be passed along to consumers. Adoption of the rule will likely damage financially many
individuals, small businesses, and smaller insurance companies. Finally, it will provide those mainly involved in selling securities the ability to suppress a valuable form of retirement savings that provides strong competition to those retirement savings offerings traditionally made by security brokerage firms.
Thank you for reading my view point in this matter.