Subject: File No. S7-14-08
From: Tim P Winders
Affiliation: ChFEBC

September 11, 2008

Insurance companies that sell EIA's should not have to have the agents be licensed to sell securities due to the fact that EIA's are guaranteed Annuities and do not lose money due to a declining market. Using a major market to guage their increases is not being invested into the market since the funds are not directly invested into the SP 500, DJIA, etc, etc.
If you want to sell mutual funds or stock, get securities licensed. Insurance companies and agents licensed to sell life, annuity, and health products should not be required to have a securities license.