Subject: File No. S7-14-08
From: James L Byrd
Affiliation: CEO Safe Harbor Financial

October 14, 2008

RULE 151 -A IS A VERY UNFAIR RULING. THIS RULING WILL DENY MANY SENIORS A SAFE PLACE TO INVEST IN A TIME WHEN THERE ARE NOT A WHOLE LOT OF CHOICES. MAKING THE INDEX ANNUITY A SECURITY PRODUCT WILL ONLY SERVE THE SECURITIES INDUSTRY, AS IT WILL ALLOW BROKERS TO GET A CUT OF THE COMMISSIONS THAT THEY ARE NOT NOW GETTING. IT WILL PUT A LOT OF AGENTS THAT DO NOT HOLD A SECURITY LICENSE OUT OF BUSINESS OR AT LEAST HURT THEIR ABILITY TO MAKE A LIVING, ALL THE COMPLAINTS THAT HAVE BEEN LEVIED ON THE INDEXED ANNUITY ARE FROM A FEW AGENTS THAT DID NOT WORK FOR THEIR CLIENTS BEST INTEREST. THE INDUSTRY HAS WORKED TO RID ITSELF OF THESE AGENTS. THIS PROBLEM HAS ALWAYS BEEN THERE IN THE SECURITY BUSINESS AS WELL.THE INDEX ANNUITY IS NOT IN ANY WAY ASSOCIATED WITH THE SECURITY BUSINESS. THE SEC MIGHT AS WELL BRING ANY PRODUCT IT SO PLEASES UNDER YOUR SUPERVISION BECAUSE THERE IS NO DIFFERENCE IN INDEXED ANNUITY AND FIXED ANNUITY OR WHOLE LIFE INSURANCE. THIS WILL ALSO SEEM TO BURDEN THE ALREADY STRETCHED SEC REGULATORY COMMITTEE IN A TIME WHEN THE COUNTRY NEEDS YOU MORE THAN EVER