I would say that this is an astute observation.
The thing that made me go 'hmmm' was when Comey said something to the effect of "Yes, Hillary is extremely careless… But no sane prosecutor would bring such a case."
What if indicting Hillary back then would have fucked up the plan in the now?
Regardless of whether Comey is in fact white or black (or even grey).. It was still a VERY curious thing for him to say…