Subject: File No. S7-14-08
From: Alex Holloman, III

August 26, 2008

I am currently a RVP with an Insurance Brokerage Firm. My history includes marketing Indexed Annuities for over 7 years. I am of the school of thought that Indexed Annuities are appropriate for the right consumer and not everyone, similar to VUL. I feel the current regulation of Indexed Annuities by the State Insurance commissioners is appropriate and sufficient. Indexed Annuities are fixed rate products with no downside or "equity" risk to the client's portfolio. These products are risk-free investments that do not need prospectus to be sold. The client's investment is not at risk and there are no market fluctuations to the account of the client. I feel Rule 151A creates an unneccessary layer of regulation, is not legally supported and it is improperly being rushed for adoption. The insurance companies that create these products are using annual options to allow the client to participate in market gains...not loses.

I wish that you would strongly reconsider this Rule and attempt to find a better solution. Today's insurance agents are trained better and understand the inner-workings of these products. The complaints for indexed annuities are minimal compared to variable annuities.