Subject: File Number S7-14-08

August 27, 2008

Ladies and Gentlemen:

I am licensed insurance agent with a securities license as an Investment Advisor Representative, and I am writing to urge you to withdraw proposed Rule 151A, which would require that sales of certain indexed annuities be made only by financial professions who have securities licenses through a broker/dealer.

Indexed annuities are among insurance company products with guarantees of safety of principal that securities do not have. Properly structured indexed annuities do not share the same investment risk as investment products such as mutual funds and individual stocks, since with an indexed annuity the risk of a downturn in the related index rests with the issuer of the product and not the consumer. Therefore, they do not truly fall under the rubric of securities.

If the underlying concern is about appropriate full disclosure by agents or the misbehavior of the minority of life insurance agents, redefining this product as a security is not the way to address this problem. I fully support efforts to discipline unscrupulous agents and remove them from the profession. The professional organization I belong to, the National Association of Insurance and Financial Advisors, is committed to working with the NAIC and state insurance commissioners towards the goal of having every state adopt and vigorously enforce the NAIC's model regulations on annuity suitability and disclosure. I also support NAIFA's recommendation that a state regulatory body be designated to develop standards for indexed annuity product design so that inappropriate indexed annuity products would be prevented from reaching the marketplace. These recommendations and not this new rule, will accomplish this goal.

I am also concerned that approval of this rule will lead to its application being extended to other guaranteed life insurance products. This is not in the public interest. Insurance products should be sold by those who have been educated in life insurance and understand how life insurance products work. In my experience those without formal training cannot offer the public the guidance and understanding that the consumer deserves.

For these reasons, I urge the SEC to withdraw the proposed rule.

Thank you very much for your kind consideration.

Sincerely,

Germaine A Hoston, Ph.D.
Investment Advisor Representative and Life Insurance Agent