Subject: File No. S7-14-08
From: Ernie Linkous, Lutcf, CSA, Cltc
Affiliation: Past president Business Network Internation, La Mesa CA

October 14, 2008

You have received many well-informed letters on SEC ruling 151A. I concur with the experts that it is NOT necessary to make any changes.

Forget everything you have read and simply, FOLLOW THE MONEY.

The real reason the SEC is doing this is simply GREED. NASD, now FINRA have lost thousands of individuals as registered representatives. In my opinion, registered individuals that pay FEES to state administrators are simply fed up with all the rules and regulations.

As a result, the insurance industry responded to consumer demand and developed FIXED indexed annuities.

Billions of dollars have been transferred from RISK, in the market, to SAFETY, out of the market. Brokerage houses have lost millions dollars. Those funds are now secured with in most cases NO fees and little or no expenses.

When moving funds from securities firms to insurance companies, this resulted in thousands of individuals and firms canceling their securities licenses costing state administrators, SEC, FINRA and NASD to lose huge sums of revenue from filing fees and commission on sales.

This is the REAL reason for this legislation.

Regards,

Ernie Linkous
President Linkous Group Inc.