Subject: File No. S7-14-08
From: Mark D James
Affiliation: Registered Representative

October 13, 2008

Without any doubt, because a fixed index annuity is an investment, it should be treated as one. Most consumers that purchase an equity index annuity including non registered insurance "salesmen" who sell them, have no understanding of how they work, and because of that reason, they should only be sold by a registered investment professional. Due to suitability and the need for compliance and oversight in this day and age it should be treated with this oversight. Just as for any investment tied to today's stock market, let alone a complex investment like an EIA with major suitability issues do to surrender charges, only a licensed securities professional capable of putting an investment "plan" together for a client should be able to represent the product.

I strongly urge the SEC to list such an investment as a securities investment only represented by a securities licensed professional. If someone wants to continue to "sell" this product, they should go through broker dealer affiliation and get the proper licensing to do so. Period.