Subject: File Number S7-14-08

August 27, 2008

To Whom It May Concern:

I am a licensed insurance professional, in practice for more than 20 years. I do not support the proposed Rule 151A, as it would apply to indexed annuities and potentially other insurance and annuity products that might fit the scope of this rule. I strongly urge you to withdraw this proposal.

In my career, I have seen rules and regulations implemented that for licensed professionals like me, are nothing less than punitive. Concerns about product disclosure, marketability and suitability are genuine and valid and should always be considered in the recommendation of any product. However, these are not pertinent to the determination of a product as a security.

It seems that what you are trying to do is prevent unscrupulous practices by licensed insurance agents who have no scruples. I applaud you for that! But Rule 151A would not address or solve this problem. The National Association of Insurance and Financial Advisors (NAIFA) of which I am a member recommends that a state regulatory body be designated to develop standards for indexed annuity product design so that inappropriate products do not reach the market and thus the people who look to us to meet their financial needs and goals. I agree with that recommendation.

Thank you for your consideration.

Helen R. Giroux, CLU
Giroux and Associates