Subject: File Number S7-14-08

October 28, 2008

I am a licensed insurance professional. I am writing to you because I do not support the adoption of proposed Rule 151A, which would classify most indexed annuities as securities. In addition, I am concerned that the application of proposed Rule 151A would not be limited to indexed annuities and that other annuity and insurance products that happen to fit the criteria set out in the rule would be brought within the scope of the rule. I urge you to withdraw the proposal.

I am all for targeting people who take advantage of people by doing bad business, but just like many insurance agent, I have helped a lot of people with the annuity needs. I dont think that just by having a series 6 or 7, means you are not going to have snakes who take advantage of people. So why punish hardworking agents who "are" out here doing the right thing for their clients to ensure they are in products that work for them. This is not the answer to ending fraud, or to stop people from practicing bad business. The Insurance agents are not the cause to the problem. Clamping down on those who do these bad things, by fines, loss of license, is the way to combat this issue.

I for one work in the community with single parents, and lower class people who are not offered the opportunity to invest even small amounts, because more advisers want to go after the big deals, which is where they make most of their money, but with some of my insurance products, my clients can have some of their payments working towards college, savings, and retirement for their children, and themselves with very affordable payments into their policy. Now if you take this away how will service this area? Not the series 6 or 7 advisers, because its not worth their time.

For these reasons, I urge the SEC to withdraw the proposed rule. Thank you for your consideration of my views on this matter.

Kezon McNeill