Subject: File No. S7-14-08
From: Michael A Davis

August 5, 2008

Re: Proposed Rule 151A

The attempt to make fixed indexed annuities a security should be stopped.

Most of the discussion I have heard is based on opinions and not as facts.

I applaud the SEC for their concern for the elderly but I think that their concern is not founded on facts. The actions of a few that have harmed consumers are very small and have been blown out of proportion. Most all states have adopted suitability standards and most companies have requirements of their own. Making this a security would not improve on this fact. The states do a good job of monitoring these efforts to weed out the bad apples.

This is a very valuable product to the senior consumer that needs a product to help keep pace with inflation without the risk to their principal. Fixed indexed annuities have guarantees of principal and guarantees of some minimum interest rate. This places the risk clearly on the insurance company and not the consumer. Therefore it CANNOT BE A SECURITY because their is no risk of loss.
IT IS WITHOUT A DOUBT AN INSURANCE PRODUCT.

This rule will only cause harm to agents, businesses, insurance companies, and the economy. It will limit access to brokerage houses that often times chose not to deal with investors that have limited assets.

The numbers of complaints from consumers have been few compared to the industry as a whole. If consumers aren't complaining then who is and why change a product that is serving the public well?

I urge you leave the fixed indexed annuity alone.

Thanks for your consideration,
Michael A. Davis
Licensed Insurance Agent
Independent Advisor Representative