Subject: File No. S7-14-08

October 14, 2008

To whom it may concern:

On 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 am an employee of Asset Marketing Systems Insurance Services, a field marketing organization (FMO) that supports independent insurance agents, whose practice includes the sale of indexed annuities to clients when they are suitable and in the clients’ best interest. As an FMO we built our 12 year old business, and still today, operate with the number one priority being what is in the client’s best interest.

These products and sales are highly regulated by state insurance commissions and the insurance carriers are also involved. The SEC proposal would impose an additional and wholly redundant and unnecessary, layer of regulation to my profession. The licensing required and the necessary affiliation with a broker-dealer is costly, very time-consuming and counterproductive. As such, it will hurt my business without benefiting consumers.

Most importantly to me is the effect that this rule (if passed) would have on the 106 employees of our company and the many other employees of all other FMOs. The rule would very likely eliminate the need for FMOs and eventually all of the employees and their jobs. Is this really what our economy needs in the long run considering that supervision already exists in the state insurance commissions? I see the SEC rule 151A as a pure money grab on a 25 billion dollar industry that has very few complaints compared to the variable annuity side already under SEC and broker dealers.

Since indexed annuity sales are regulated more than adequately by the state insurance commissions, the SEC’s proposal merely adds to governmental bureaucracy without providing consumers with additional protection. Suitability rules in both the insurance industry and the securities industry mirror each other. Moreover, since dispute resolutions within the securities industry take much longer, are more complex and are much more costly for the consumer than those overseen by my Department of Insurance, what is proposed will substantially hurt consumers rather than help them.

I strongly urge that proposed Rule 151A not be enacted. It is unnecessary, redundant and counterproductive.

Kind regards,
Chris Gladheim
Director, HR & Operations
Asset Marketing Systems