November 17, 2008

Subject: AGAINST RULE 151a s7-14-08

To whom it may concern:

I am currently an insurance agent (since 2006) and securities licensed series 6 & 63. It has always been my understanding that a savings vehicle, guaranteed to be worth more tomorrow than yesterday, having no potential for loss of principal, was not and could not be considered a security. These vehicles are issued by banks and insurance companies with a stated guaranteed minimum interest rate either for the duration of the holding period or as a lifetime minimum rate of return.

Fixed index annuities fall under the definition above, are accepted by the consumer as no-risk investment alternatives and SHOULD NOT BE registered or considered as investments that entail the possibility of a reduction in principal value during the holding period. As a matter of fact, if the deposited, invested or premium paid amount of the consumer into a fixed annuity is compromised in some way, either the Federal government or State government is responsible within certain limitations, to refund these losses. The same cannot be said for securities and therefore the conclusion MUST BE, that fixed annuities of all type, index or traditional are NOT securities and should not be treated as such.

Respectfully submitted,

Bill Romeo