Subject: File No. S7-14-08
From: Doug C Roberts
Affiliation: Annuities Recruiter and licensed agent

November 17, 2008

SEC,

I'm a licensed agent and recruiter in the annuities market. Member of the NAFA. I oppose 151a.
All of my past and present customers have lost no money in the recent market crisis. They are also looking to move more money to annuities as a safe haven during this economic crisis.
The proposal is not supported by any empirical evidence that supports the Commission's claim that widespread abuses in the selling the product exist.
The Commission's action would restrict public access to an increasingly popular product.
The appeal of indexed annuities is that they are not securities and not subject to risk of loss from market activity.
They are subject to comprehensive state insurance regulation.
Thank you for taking the time to hear me out.
Doug Roberts