November 17, 2008

Subject: Rule 151A s7-14-08

Since today is the deadline to comment on Proposed Rule 151A, I thought it my duty to write in opposition to the rule.

My name is Danny M. Moore and I am a member of MDRT; FPA; NAIFA and NAFA. I have been in the financial services business since 1982. I am not writing to cite any "horror stories" as one of my professional associations encouraged me to. I simply believe that fixed index annuities are not securities and are no more abusive to the public than Fannie Mae, Freddie Mac, Government Bailouts of Private Enterprises, Whole Life, Variable Annuities, the declining economy and the list goes on and on. I also believe that the State Insurance Departments are closer to the people and that one financial entity- fixed indexed annuities does not need to be bureaucratized anymore than it already has. I believe the media also does a good job of providing information on financial products being offered to the public. My real concern is whether this is being proposed to protect the consumer or just another power play by the securities industry vs. the insurance industry over who rules the roost. I oppose Rule 151A.

Sincerely,

Danny M. Moore
Moore Financial Management