Subject: File No. S7-14-08
From: Joshua Cleary

August 6, 2008

To Whom It May Concern:

I am writing you today in response to SEC Rule 151A regarding the treatment of index annuities as securities. I am urging my colleagues to stand up against this unnecessary rule.

Currently, I hold both an insurance and securities license and offer index annuities to retirees and pre-retirees as a part of my financial advisory practice here in Columbus. And, while rule 151A would not prohibit me from selling IAs (in whatever form), it would have a severely negative impact on my business, as well as my clients, who seek to have a simplified, yet financially sound retirement. Secondly, I urge you to consider the media effect and panic syndrome which comes from enacting such regulation. It will most likely create confusion and uncertainty for thousands Central Ohioans and possibly millions across the country. Finally, please consider the thousands of licensed insurance professionals that will have their businesses negatively impacted by this unnecessary rule. Self regulation is the key to success for all.

This country simply does not need any more financial worry or rules that manufacture it.

In closing, please stand against SEC Rule 151A.

Thank you for your time and service,

Joshua Cleary
Financial Consultant
Ohio