Subject: File No. S7-14-08
From: THOMAS V HAMMOND
Affiliation: LIFE AGENT

September 5, 2008

I am opposed to implementation of SEC rule 151-A. Why is this reg needed? Will consumers be better served by fewer options? Annuities are insurance products, whether they are based on interest only, or linked to performance results of various indexes. Unlike securities, the annuity owner does not own actual shares of stock in indexes, rather the insurance company has purchsed options. With the guarantees of an fixed index annuity, there is no chance of losing money in a down market. As an insurance product, being able to pass the account to hiers upon death is a big advantage, bypassing probate.
Should this rule be implemented I believe that those who wish to sell annuites be required to obtain the appropriate insuance license as we insurance agents will be requires to get another license.
Thank you tom hammond