Subject: File No. S7-14-08
From: Terry V Neustrom
Affiliation: Independent Agent

September 4, 2008

I am writing to strongly oppose the SEC's draft regulation rule 151A which tries to change fixed index annuities from insurance products into securities products. Fixed index annuities were invented by the insurance industry and are already heavily regulated by the states' insurance divisions. They allow clients to protect and insure their retirement assets and give clients sound guaranteed safe alternatives to volatile market securities. I find it repulsive that one can read daily in publications such as the Wall Street Journal the constant problems the SEC has in regulating questionable hedge funds and quant funds that have upset the basic economic structure of the country. And to now think that the SEC should now be able to regulate insurance products is beyond belief. If the SEC, in coordination with the states' insurance divisions wants new educational designations or additional suitablility training for insurance agents that would be acceptable. The SEC has enough problems regulating questionable securities products and brokers. Keep fixed index annuities where they belong, as insurance products. Thank you. Terry Neustrom