Subject: File No. S7-14-08
From: Jeffrey J Kirkman

June 30, 2008

It is about time that EIAs be treated the way they are being sold as a security. Most of these contracts are so complex in their crediting methods, you need a Ph.D in Math to figure it out. I would submit to you that most insurance agents could not explain how these EIAs operate. Most agents are selling them as "safe" investments. "Get the upside of the market without the downside." You should also look into the firms that market this stuff and make them register as B/Ds.