November 18, 2008

Subject: FILE NO, S7-14-08

I OPPOSE THE IMPLEMENTATION OF RULE 151A.

I HAVE OVER 20 YEARS EXPERIENCE THE FINANCIAL SERVICES INDUSTRY& SERVE OVER 300 CLIENTS PER YEAR. I THINK THIS RULE WOULD IMPOSE UNNECESSARY REGULATIONS, BURDENS, & BARRIERS ON THE FINANCIAL PROFESSIONALS & CLIENTS. OUR CLIENTS HAVE BEEN EXTREMELY PLEASED WITH THE PERFORMANCE & SAFETY THAT THEY EXPERIENCED WITH EQUITY INDEXED ANNUITIES.

THANK YOU FOR YOUR TIME & ATTENTION TO THIS MATTER.

DERRICK L. ALFORD, REGISTERED FINANCIAL CONSULTANT, PRES.

FISCAL FITNESS FINANCIAL SERVICES, INC.

RICHMOND, VA. 23222