Subject: File No. S7-14-08
From: gerry bielawski
Affiliation: sales

September 10, 2008

I would like to respond to proposed rule 151A.

i feel that indexed annuities are NOT securities, because there is NO RISK to the client if the market goes down. With a securitiy, you can lose money in a bad market. In an indexed annuity, you either stay where you are (until the market again goes up, or you can earn a minimum amount of interest....NO DECLINES, LIKE STOCKS, MUNI BONDS, VARIABLE ANNUITIES ETC.

Therefore I feel that you should NOT PASS RULE 151A.

G. B.