Subject: File No. S7-14-08
From: Fred H Marshall
Affiliation: ChFC, CLU

July 16, 2008

I oppose the proposed 151a rule because:

1. Fixed Index Annuities are already regulated by insurance laws.

2. The interest credited is based on index returns but the investor is not directly investing in the index.

3. Fixed Index Annuities crediting rate can vary with the index returns. But so can the interest paid on fixed interest products. Their rates can change each year with interest rates changes, but these are not considered securities either.

4. The investor is not risking principal.

5. Fixed Index Annuities have a very low complaint percentage (see Advantage Compendum, https://www.quote-and-apply.com/amigo/?referid=9870-9069)