Subject: File No. S7-14-08
From: James L. Byrd
Affiliation: Registered Representative

August 6, 2008

Ruling 151A –

While your attempt to supervise index annuities is an honorable intention, I find the only people you are hurting are the ones you are trying to protect.

Index annuities are very practical solution for many risk adverse clients.

By bringing the index annuity under the control of a broker dealer, you are providing a commission to the broker dealer and not controlling unethical practices. Our industry has taken tremendous steps to resolve such issues by stepping up suitability and compliance. Are you aware that unethical practices in the non-security side are not, as a percentage, any higher than the security side?

We have one rogue company that gave a bad name to all of us. In short, the index annuity is not a security product and your ruling should not hold up in a court of law. It has not held up in the court of public opinion by NAIFA and the thousands of agents that will be affected by your proposed.

You will only cost taxpayers millions of dollars to fight a useless ruling not to mention costing the consumer a great product