Subject: File No. S7-14-08
From: Michael A. Dinich
Affiliation: Registered Rep

July 8, 2008

I oppose the adoption of proposed rule 151a by the SEC for several reasons and feel that the SEC is exceeding its authority in creating this rule.

Individual who purchase Indexed Annuities, are not exposed to investment risk. Since the underlying value of an Indexed Annuity is guaranteed by the claims paying ability of the Insurance Company.

I understand the intent of this ruling is protect consumers, however, consumers do not accept any additional risk in a EIA than they would in a variable fixed rate annuity. Would the SEC then view Variable Fixed rate annuities as a security?

If so will the SEC then include the Sale of Equity Indexed CD's to the list of registered products, or even variable rate annuities for that matter?

Would a 32 plus page prospectus accompanying an Equity indexed annuity, make the purchase of an annuity harder or easer for the consumer?