Subject: File No. S7-14-08
From: Joseph Watson
Affiliation: Independant Insurance Agent

September 5, 2008

As an independant insurance agent who is licensed to sell securities, I suppose implementing SEC Rule 151A would help me by eliminating some of my competition. However, I fail to see how Indexed Annuities could be considered securities. No security in the world can guarantee that account values will never go backwards. If you consider indexed annuities to be securities, then we should also consider money markets, CD's, Savings Accounts, etc., to be securities.

I realize that there are advisors out there who are taking advantage of people (seniors in particular), and we need to take steps to stop them. However, the vast majority of advisors out there are doing it right Furthermore, implementing the above Rule wouldn't change anything for the few bad eggs out there. They would simply get thier securities license, and continue the abuse. If you want to regulate these products, regulate them through the Insurance Departments where they are supposed to be regulated.

Indexed annuities are NOT SECURITIES, and should not be considered to be so

Thanks for your consideration.

Sincerely,

Joseph R. Watson, CLU