Subject: File No. S7-14-08
From: Dennis K Bertrand, LUTCF
Affiliation: Independent Insurance Producer

August 1, 2008

1 August, 2008

Please reject proposed Rule 151A.

FIA's are not securities and are bought by consumers who want safety of principal with the added benefit of earning market interest rates greater than what may be available in a traditional fixed interest annuity. There is no compelling reason for SEC involvement in the regulation of these investments.

'Indexed annuities do not apply negative changes in an index to contract values. Thus, if the index value is negative over the course of a crediting period, no deduction is taken from contract value.' This statement, extracted from your summary, shows that the risk in an FIA is not market driven and should remain outside the regulatory authority of the SEC.

Thank you for your consideration. May common sense lead you to conclude that additional regulation of fixed index annuities is not in the consumers best interest and will place a huge burden on the average insurance and annuity producer.

Sincerely.
Dennis Bertrand, LUTCF
Clarksville, Tennessee