Subject: File No. S7-14-08
From: Michael G Constantinou, CSA

November 1, 2008

I am opposed to the SEC's proposed Rule 151A,defining all fixed indexed annuities as securities. You did little to police unethical practices by security companies and their representatives, which brought about economic problems in 2001. You did little to police unethical practices brought about by security companies and their representatives, which, with the help of Congress and their banker friends, brought about today's economic problems. And, when an insurance agent is licensed to sell variable products, and then sells those products through churning, you go after the life company, and not the agent. How many times do investors have to lose their retirement plans before you become a true watch-dog over your representatives who are expected to follow the SEC rules of conduct? How many more times do people have to lose their insurance policies before you become a true watch-dog over those agents who are expected to follow the SEC rules of conduct? And now, to make you feel good, while investors are hurting, you want to oversee fixed-indexed annuities. You can't get your own house to stand on solid ground, so you decide to take over a program that individuals trust more than investing directly with the companies and representatives you can't oversee. You can DO or NOT DO whatever you want with the direct sale of stocks, bonds, and mutual funds and you can DO or NOT DO whatever you want with the sale of stocks, bonds, and mutual funds through variable life insurance and variable annuities. BUT, leave fixed-indexed annuities alone. People trust them