Subject: File No. S7-14-08

September 16, 2008

June 25, 2008, the United States Securities and Exchange Commission proposed a new Rule 151A that would, in effect define most indexed annuities as securities. I AM WRITING TO OPPOSE THIS PROPOSED REGULATION.

I have been in the insurance business for 32 years, and my practice does include the sale of indexed annuities. I make sure the annuities are suitable and in the best interest of my clients. Indexed annuities are popular retirement savings tools, particularly in these uncertain times. Consumers are looking for a safe and secure place for their money, and I feel the indexed annuities are an option for many of my clients.

The sales of indexed annuities are highly regulated by our state's insurance commission, and also by the insurance carriers involved in the sale of the indexed annuities.

I feel the SEC proposal would impose an additional, and definitely redundant and unnecessary regulation to my profession. The licensing required and the costly affiliation with a broker-dealer is time consuming and is not beneficial to me. I also feel my business will suffer, and the Rule 151A will not benefit consumers.

Indexed annuities are adequately regulated by the state insurance commissions, and the SEC's proposal does not provide any additional protection to consumers. Suitability rules are most strict in the insurance industry, and the securities industry just mirrors the rules of the insurance industry.

I am very concerned about my clients, and all consumers for insurance products. I do not feel Rule 151A will benefit the consumers, and it may even hurt them. I know it will also hurt my business that I have worked so hard to build up. This proposed rule will not provide the consumer with any better or different protection.

I believe the State Insurance Commission has done a fine job in regulating in the indexed annuities, and I believe that along with the insurance carriers involved with indexed annuities, they are protecting the consumers most adequately.

I strongly urge that proposed Rule 151A not be enacted. This rule is unnecessary and will hurt in independent insurance professional like myself.

Respectfully submitted,

Beverly J Smock, Insurance Agent