Subject: File No. S7-14-08
From: Paul J Cross
Affiliation: CEO ANBC - Annuity National Brokerage Co

October 27, 2008

Rule 151A is hereby again challenged.

Fixed-Indexed Interest Rate Annuities have proven again and again to be without RISK and once again maintained their value without loss during the recent market crises where headlines have read 401K Owners Lose $2Trillion... and losses have continued since.

Perhaps Risk FREE is not your challege afterall FIAs are not bought, sold, or traded on Wall Street or any other Exchange.

Why are FIAs SAFE?

FIAs are SAFE because they are legislated and regulated by State Insurance Commissioners - every state has one - and scrutinized by the National Association of Insurance Commissioners.

So what is your challenge?

What ever it be, consider the loss of confidence and trust the insurance industry and insurance agents would face if annuity owners were to discover the SEC is now regulating their annuities. It just might cause panic and disbelief in the safety of their annuity with fear that it has the potential for big losses and no longer guarantees income for life.

I think most people would agree that you have your hands full just to restore Wall Street and let us not forget that main street is connected to Wall Street... it is main street that drives Wall Street and you have the obligation to restore Wall Street and help people recover their 401Ks.

Now consider this: Many people age 70-1/2 and over are forced to take RMDs from 401Ks and other retirement plans in the market - they are now forced to sell at a loss of which they can never recover because the shares sold at a loss to cover the RMD are gone.

The State Insurance Commissioners and the National Association of Insurance Commissioners are to be commended for their job in legislating, regulating, and supervising the sale of insurance products which include the Fixed-Indexed Annuity.

We justly and rightfully opose Rule 151A.

I sincerely ask you to reconsider and step-up to the plate for better supervision of the SEC and respectfully acknowledge that the State Insurance Commissioners are to be commended for a job well done.

Thank You,

Paul J. Cross