Subject: File Number S7-14-08 - IN SUPPORT OF

August 27, 2008


I am a FINRA registered representative and licensed insurance professional in Florida. I am writing to you because I FULLY support the adoption of proposed Rule 151A, which would classify most indexed annuities as securities. As a veteran registered representative who must conduct business as set forth by FINRA regulations, I'm not concerned about other insurance or annuity products being effected by this rule. Regulated full disclosure, suitability, and marketing are all necessary to curb the abuses by non registered agents on indexed annuities in the marketplace today. I urge you to continue pursuit and passage of this proposal.

As an agent working with clients daily, very few understand the indexed annuity the have invested in nor do they understand participation rates and other components of this highly technical product. Returns on this product are tied to the financial markets and although this product doesn't share the same market risk as other registered investment products, the marketing of this product promises market returns with no downside risk.

In my opinion state regulation of indexed annuities is inadequate at best. I as a 20 year member of the National Association of Insurance and Financial Advisors disagree with NAIFA's stance on this issue. SEC / FINRA regulation of Indexed Annuities annuities is long past due and I urge continued support of this proposed regulation.

Thank you for your consideration of my views on this matter.

Dave Grantham, CFP(R)
Prudential