Subject: File No. S7-14-08
From: Craig A Ramsey
Affiliation: CLU, ChFC

August 26, 2008

I oppose the adoption of proposed rule 151a. The SEC has no valid authority in this area, and the Executive Summary provided contains incorrect statements and presumptions that illustrate the ignorance and bias inherent in the agency, and foreshadows unfair and incompetent regulatory bias should the agency prevail in this attempt.

Fixed index annuities are not securities as they expose the owner to no market risk to their principle the only variable is how much, if any, gain they will experience.

The current insurance regulatory model offers consumers a superior regulatory process.

This attempt to expand the agency's influence into an unauthorized area for non-securities products is unwarranted and not indicated by scope or nature of the occasional inappropriate transaction, the nature of the underlying investment, or the charter of the SEC.