Actions Layer! Top or bottom of timeline?

When I first started using Flash, I stuck the actions layer at the bottom of the timeline. I also noticed that Lee Brimlow from gotoandlearn puts his actions layer at the bottom too.But then a mate of mine saw how I worked and told me I should put the actions layer at the top of the timeline. He pointed out that if the actions layer was at the bottom and I had a lot of layers, I would be constantly scrolling down to that layer. Which is true. He followed this saying that Flash loads from the bottom up (if specified in publish settings) and if my code was referencing certain clips that it wouldn’t know where to look because the clips are on a separate, later layer which was to be loaded.Is he talking mumbo jumbo? Where do you guys put the actions layer?