Subject: File No. S7-14-08
From: Elthello Smith
Affiliation: Independent Insurance Agent

July 30, 2008

I offer my very strong objections to rule 151A. If the SEC was interested in doing what is best for the public, it would look more closely at the securities industry and the way it conducts its business.

The Fixed Indexed Annuity is a safe, well defined savings product that offers no risk to the client, but does offer upside potential if the linked index goes up. There are no sales, administrative or other management fees associated with the Fixed Index Annuity if held for a minimum period. The Fixed Index Annuity gives the client peace of mind in knowing that their funds are not at risk in the market. In the worst market year, the client does not lose money, thereby preserving their savings.

This savings vehicle gives the client something they did not have until the Insurance industry, NOT the Securities industry, began offering and marketing the Fixed Indexed Annuity in the mid 1990's.

Your passage of rule 151A effectively eliminates all competition for the savings dollar. I sincerely hope and pray that it will be overturned when challenged in Court.