Subject: File Number S7-14-08

August 27, 2008

To the SEC from my personal email address,

I am a well respected insurance professional with 15 years of experience in the insurance industry and have been serving my own clients for close to 5 years. I am ethical to a point that exceeds any state or federal requirements and have many clients that's will testify to that extent.

The new Proposed Rule 151A is terribly unnecessary. A few bad apples should not spoil the good work that most of us do. Independent insurance professionals feel that broker/dealers are upset that they are not getting their cut from the tremendous amount of money that is being placed into Indexed Annuities. We feel this is whats driving this silly dispute. Indexed Annuities put no client principal at risk with guaranteed interest rate return if the money is untouched for a period of time. I always inform clients of worst case senarios if they need to pull their money from the product.

US Supreme Court and other judicial decisions have clearly stated fixed indexed annuities should not be regulated as securities.

Fixed Indexed Annuities are terrific products by helping my clients stabalize the volatility of their market portfolio risk. Criticism has been exaggerated. Abuse of any financial product will occur if the trusted advisor cares more about his pockets more than the clients. This activity cannot be blamed on a product.

Proposed Rule 151A is being rushed to adoption, is not legally supported, creates a layer of regulation that will cause consumer confusion and increase portfolio/economic disruption.

Michael A. Mendonca FLMI, ACS
Mendonca Insurance Services