Subject: Rule 151A

August 27, 2008

In my opinion indexed annuities can be complicated and the sales process can be manipulated. If a product has a relationship with securities I think the agent needs to be very familiar with securities and I don’t think you learn about the securities market by reading a product brochure. If you don’t have a securities license or cant get one maybe you haven't achieved a level of sophistication required to sell such a complicate product. Rules are in place to protect consumers and producers, follow the rules and we are all ok. I guess I don’t see the draw back of having the SEC overseeing a product with a relationship with the securities market after all the securities market is not hypothetical. JB

James Briggs
Financial Representative
"Financial Security Doesn't Happen By Chance"
The Zack Group