October 31, 2008
I do not support adopting Rule 151A which would classify most indexed annuities as securities.If adopted I am concerned it would also negitively impact other insurance products.I agree that individuals who engage in unsuitable and misleading sales practices should be dealt with appropiately, however the classification of the product is not going to solve that problem.I believe the indexed annuities should be left as an insurance product and the states insurance regulatory offices does a great job addressing the concerns raised by the SEC.Please withdraw the proposed Rule 151A. I thank you for the opportunity to comment on this ruling