Subject: File No. S7-14-08

December 1, 2008

Dear Mr. Cox,

I am a insurance liscensed professional serving my clients in the life/health/disability/annunity arena and I have been in this industry for about 20 years. In that time I have worked for big firms, small firms, and have been on my own as a solo business owner and service provider. I have held a securities liscence a couple of different times in my work history, so I am familiar with both sides of the agruements regarding 151A.

This is how it looks to me:

There are two young boys playing out in the playground, and one boy begins to get more attention from the pretty girls than the other boy does. Rather than trying harder to compete for the attention of the girls, the loser boy complains to the teacher that this is unfair, and that the teacher should bring the other boy in from the playground (leaving the pretty girls no one to look at but him) The teacher who has been feeling rather underappreciated lately, is looking for a reason to exert his authority, and in the name of playing fair, is considering doing just that.

Indexed annunities are an insurance product, they are not a security product. If the interest rate on a passbook savings account at a bank was linked to the return of the S&P 500, it still would not make it a security product. It would still be a passbook savings account! Indexed Annunities are just that: Annunities, and thus should rightly fall under the oversite of the Insurance Commissioners.

I urge you on behalf of my clients and of all those who are providing financial services to the public to abandon this attempt to re-classify indexed annunities as a security product, thus removing one of the valuable tools we have to help our clients. A close look will reveal that this is not really about all the things it claims to be about....it is really about a convienent excuse to grab power from the effect, and give it over to the ineffective in the name of (pick what ever excuse you want to use in this space_______). Please do not do this.

Thank You

Sincerely

Brad Barnhart MBA