Subject: File No. S7-14-08
From: Thomas M Martin

September 4, 2008

I am a registered representative so reclassifying indexed annuities would not prevent me from selling them. That being said, I think it is a bad idea to reclassify them as a security.

If the fact the EIA's are expected to increase in value is sufficient evidence to call them secruities, where does it end? I would not have purchased my home unless I thought it would increase significantly in value does the SEC plan on taking on real estate agents next? What about my art collection, which I also expect to increase in value will my art broker need to comply with SEC requirements?