Subject: File No. S7-14-08
From: Jeff Miller

August 29, 2008

To call a EIA a security is a completely false statement. My clients who have purchased these products from me did so to protect their assets not have them be reduced like they would in a mutual fund. If you enact this proposal where will I put the money of these clients? You will be the ones responsible for them losing money if the market declined.

With EIA my clients have no investment risk whatsoever.

This is an issue of Wall Street having the upper hand just as they have been in the last few years. Who are the firms that are being fined these days? It's the largest firms. And now you want to turn all of this over to their type of jurisdiction. I think it would be wise to reconsider and bring some sanity back to the forefront.

Just as I cannot call an apple a banana, you if taken in some thoughtful consideration, cannot call and EIA anything but a fixed product.

Consider all of the facts before you make a decision that will affect not only us as agents but the consumer and the entire economy.