November 17, 2008

Subject: AGAINST RULE 151a s7-14-08

To whom it may concern,

I have been a licensed, practicing insurance agent since 1987. I also received my Series 6 securities license in 1988 and the Series 65 in 1999. Throughout the past 21 years, 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 SOULD 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, "premium paid" by the consumer into a fixed annuity is compromised in some way, either the Federal government or State government is responsible, within certain limits, 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,

Harvey H. Meldrum