November 17, 2008

Subject: Rule 151A s7-14-08

To Whom It May Concern:

I have been licensed to sell life insurance for over 15 years and have a series 6 securities license for over 12 years. It has always been my understanding that a savings vehilce guaranteed to be worth more tomorrow than today or yesterday with NO potential loss of principal should NOT be considered a security. These types of savings vehicles with a guaranteed rate of return and guaranteed principal are issued by Banks and Insurance Companies and regulated by the Banking and Insurance Commission.

Fixed index annuities fall under this guaranteed type of vehicle and SHOULD NOT BE CONSIDERED an investment with the possibility of a loss of principal during their holding periods. As a matter of fact, if the premium deposited into one of these fixed index annuities is compromised, the Federal & State Government, with certain limitations are responsible to refund these losses to the consumer or account holder. The same can not be said for securities. It is the opinion of this licensee that fixed indexed annuities are NOT securities and should be left with the the Insurance Regulators for control and consumer protection without intervention from the SEC.

Respectfully Submitted,

Paul J.Edmunds, CFP,CPA