Subject: File No. S7-14-08
From: Cameron S Dressander

August 8, 2008

I STRONGLY OPPOSE RULE 151A FOR MANY REASONS.

WHILE I APPLAUD THEIR EFFORTS TO PROTECT CONSUMERS, THIS RULE WILL NOT ACCOMPLISH ANYTHING MORE THAN THE CURRENT SUITABILTY PROCEDURES ALREADY IN PLACE WITH EVERY CARRIER THAT OFFERS FIXED INDEXED ANNUITIES.

THE PROPOSED RULE, IF PASSED, WILL CAUSE HUNDREDS OF THOUSANDS OF AGENTS AROUND THE COUNTRY TO LOSE THEIR MAIN SOURCE OF INCOME, NOT TO MENTION THE CARRIERS, INDEPENDENT MARKETING COMPANIES AND THEIR STAFF. THE FINANCIAL IMPACT ON THE INDUSTRY WOULD UNDOUBTEDLY BE DEVESTATING.

SINCE THEIR INCEPTION IN THE MID 1990'S THESE PRODUCTS HAVE DONE EXACTLY WHAT THEY WERE DESIGNED TO DO-PROVIDE CONSUMERS WITH A PRODUCT WITH MINMUM GUARANTEES,SOME UPSIDE POTENTIAL, LIQUIDITY, TAX DEFERRAL AND AN OPTION FOR SOME OF THEIR DOLLARS SET ASIDE FOR RETIREMENT THAT THEY CAN NOT AFFORD TO LOSE. IS IT REALLY RIGHT TO TAKE THAT VERY IMPORTANT OPTION AWAY FROM MILLIONS OF AMERICANS THAT NEED THIS SAFETY?

WE ALL KNOW WHAT THE STOCK MARKETS HAVE DONE TO MANY AMERICAN'S RETIREMENT NEST-EGGS. DO YOU THINK THESE CONSUMERS (WHO WOULD HAVE CONSIDERED A FIXED INDEXED ANNUITY) WERE/ARE READY TO SEE THEIR ACCOUNTS GO DOWN 15%-25% WHEN THEY ARE GETTING READY TO RETIRE? WE SEE THIS TYPE OF THING EVERY DAY AND FOR MANY OF THESE PEOPLE, FIXED INDEXED ANNUITIES ARE THE BEST OPTION BECAUSE THEY CAN SLEEP AT NIGHT KNOWING THEIR MONEY IS SAFE AND CAN ONLY GO IN ONE DIRECTION-UP. RULE 151A WILL ABSOLUTELY MAKE THESE PRODUCTS OUT OF REACH FOR THE MAJORITY OF CONSUMERS BECAUSE MOST LIFE AND HEALTH AGENTS WILL SIMPLY NOT GET A SECURITIES LICENSE TO SELL FIXED INDEXED ANNUITIES. THESE PRODUCTS ARE NOT SECURITIES BUT LIFE INSURANCE PRODUCTS AND THESE AGENTS DECIDED NOT TO WORK IN THE SECURITIES INDUSTRY FOR A REASON. IS IT FAIR TO TAKE THIS VALUABLE OPTION AWAY FROM THIS ENORMOUS NUMBER OF AMERICAN HOUSEHOLDS AT A TIME WHEN IT IS NEEDED MOST? THE AFFECTS OF THIS PROPSED RULE WILL BE MORE FAR REACHING THEN THE SEC REALIZES. LET THE INSURANCE DEPARTMENTS AND THE CARRIERS DO THEIR JOBS.

PART OF THE "COMPLAINT" HAS BEEN THAT THESE PRODUCTS ARE BEING SOLD INCORRECTLY TO SENIORS. IT'S PROBABLY TRUE THAT SOME AGENTS HAVE NOT DONE ENOUGH TO EDUCATE THEIR CUSTOMERS ON ALL THE IMPORTANT FEATURES OF THE PRODUCTS. THIS IS OBVIOUSLY TRUE IN EVERY INDUSTRY, INCLUDING THE SECURITIES INDUSTRY. AS I'VE MENTIONED, HUGE ADVANCES HAVE BEEN MADE ON SUITABILTY AND WILL CONTINUE TO BE MADE IF ALLOWED. LET THE INSURANCE INDUSTRY "WEED" OUT THE BAD APPLES, CONTINUE ON THEIR QUEST FOR SUITABILTY STANDARDS AND LEAVE THE INDUSTRY TO SELF REGULATION.