Subject: File No. S7-14-08
From: michael j kavanagh
Affiliation: Certified Financial Planner, Chartered Financial Consultant, Chartered Life Underwriter

July 10, 2008

EIAs SHOULD be treated as securities. We're dealing (directly or indirectly) with returns based on changes in the index. Anybody who doesn't have a securities license has absolutely no business advising a client about anything related to securities. Period.