Subject: File No. S7-14-08
From: Lucas Renfroe
Affiliation: CEO, American Liberty Financial Group

September 2, 2008

I agree, Equity Index Annuities do need some reform in sales practices...But, labeling them as securities is definitely not the answer. Insurance agents should have to do extra continuing education or obtain a certain certification before being able to sell Equity Index Annuities, or any annuities. But putting a label on EIAs that says they are securities is fraud. An EIA is in no way a security. If an EIA was created as a security, it would have started out as one. This is a stupid way to fix a complex problem. You will still have idiots that have a securities license selling these things. Not to say that all licensed securities dealers are idiots, nor are all insurance agents that sell them. But that is the problem. Whatever you label them they will get sold wrongly unless you come up with an EIA license or certification to sell the products.