Subject: File No. S7-14-08
From: John P. O'Gorman

October 13, 2008

Dear Sirs,

As an insurance agent in Massachusetts, I am amazed that the SEC are considering regulating Equity Indexed Annuities as if they were stocks. EIAs, which participate in the gains of the stock market, but with no downside, are a completely different product - an insurance product.

The proposed Rule 151A is an unwarranted intrusion on the insurance industry, which is well-regulated by insurance commissioners in the individual states.

Might I suggest that your efforts be put to better use in regulating the stock market, which has been suffering some upheavel lately?

The SEC and individuals within it might find themselves civilly, if not criminally, liable if they interfere with the livelihoods of those in the insurance industry.

Yours Sincerely,

John O'Gorman