Subject: S7-14-08

September 4, 2008

With reference to proposed rule, 151a, I would like to make the following comments:

Fixed Index Annuities provide a unique benefit to people , particularly those nearing or already in retirement. Qualified or Non-Qualified money can be put into Fixed Index Annuities that have Lifetime Income Riders guaranteed by the Insurance Company. In other words, they don't have to worry about running out of money in retirement or about Stock Market fluctuations.

At present, this benefit rider is only available through Fixed Index Annuities, offered by Licensed Insurance Agents.

If the law is changed to require Insurance Agents to become Security Licensed (Stock Brokers), very few people will have the opportunity to have this Lifetime Income Benefit. The'll be offered mostly market risk securities.

Presently, sales of Fixed Index Annuities are highly regulated by state insurance departments. Additional securities regulation will add little benefit to consumer protection. It will only limit the availability of these minimum risk retirement products and put many top-quality Insurance Companies out of business.