Subject: File No. S7-14-08
From: Arthur J. Fredericks, Jr.

October 29, 2008

I am licensed in the state of Virginia to sell and service Fixed Annuity, Life and Health since 1971. I am consistently productive. Since 1997, I have sold about 80 to 100 new FIA apps with a volume of 2 to 3 million every year. The quality of what I do, results in most of my business being referral from well-established and satisfied customers.

I understand that some agents, that OCCASIONALLY sell FIA, are not credible. As with any business, whether it be monitored by the aggressively biased, and greedy broker dealers, or on the other side of the coin, by credible authorities or regulators such as the SEC and the NAIC, there will always be bad sales people. I do not see where the SEC supplanting the regulatory authority of the NAIC will benefit the FIA consumer. Although, I do clearly see where it will befuddle the FIA consumer.

Take a look at where the motivation of where proposed rule 151A comes from. It is obvious that the broker dealers are losing ever increasing income from the sale of FIA by agents who are not in their grasp. As a result the broker dealers have spent much time and money lobbying to require these agents to bring in, their tightly maintained loop, the very significant money they are losing. As you know, money is why things are accomplished or not accomplished. This is clearly evident with the push of the broker dealers to capture and recapture their loss of it through proposed rule 151A.