Subject: File No. S7-14-08
From: Thomas M Ungrady
Affiliation: Div. Mgr.

October 13, 2008


Financial instrucments that the public didn't, and still doesn't, understand has brought the United States to its' economic knees. I believe the true target of finger pointing belongs with lack regulatory oversight.

Equity Indexed Annuities are another misunderstood financial product that people, young and old, are urged to place their money into with no understanding of the complex moving parts of caps, participation rates, or even the index that the annuity is linked to. Insurance agents with little to no understanding of the markets or the index are encouraged to package everyone into the product. The lack of state regulation and accountability of the seller leads me to one opinion.

Regardless of whether the EIA comes under the definition of a security or not, the product must be supervised by the SEC, FINRA, and a broker-dealer (whose very existence is in jeopdardy if it permitted unsuitable sales)where more regulatory oversight would be provided and consequences exist.

I am not moved by insurance companies who complain about the cost of registering their products. Had they been more concerned with suitability... this process would not be taking place. I, also, am not moved by insurance agents who complain that they would have to obtain a series 6 license. The series 6 exam is not a mountain to climb if one were serious about their involvement in the financial services field.