Subject: File No. S7-14-08
From: Dayne A Clayton

August 25, 2008

I am commenting on proposed rule 151A, requiring Indexed Annuities be treated as securites products.

Indexed annuities have been successful because of the nature of the product meets the needs of many clients, who wish to protect the principal and still maintain a safe rate of return.

They are free from adverse risk of the equities market where clients can (and do) lose their principal.

They offer important protections, (1) the guarantee of premiums paid and (2) guarantee of interest credited.

They provide underlying interest guarantees required by state law. Both forms of annuities, fixed and indexed, the policyholder is at risk to the insurer's annual interest rate declaration, whether it is an expressed percentage amount or a foumula relating to changes in an index.

Keeping the supervision of indexed annuiites at state level will keep the cost of federal supervision from being passed on to the consumer.

Broker/Dealers are trying to surppress a viable, valuable and successful retirement savings product that provide strong competition to them.

Please look at this correctly and do not overburden consumers who just want a product that keeps their savings safe without the complications of trying to second guess the equities market.