Subject: File No. S7-14-08
From: Mark Hartmon

October 13, 2008

Agents who are ONLY Licensed by the States for TRADITIONAL Insurance products (Interest Rate Sensitive) NEED EIAs to look like their are Financial/Investment Advisors. They do NOT want to appear to be merely an Insurance Agent, which most consumers equate to a car salesman, etc.

They CERTAINLY discuss SELLING Securities, which requires a Registration

State Insurance Regulatory Agencies are pathetic Other than collecting fees, they are typically run by Politicians appointed by the Govenor, when they loose a race, and are looking for a favor/job. They know little to nothing about the Insurance/Risk Managment business.

EIAs are complex, and have too many moving parts. There should be a seperate line item Disclosure Document required to be Initialed by the client. There should be a seperate Suitability document, that includes work history, occupational experience, aka sophistication as to SUITABILITY.

EIAs are all about being tied to EQUITY INDEXES, therefore un-registered agents are discussing issues that require a FINRA registration, which they do not have

Require Registration If an Agent is ONLY licensed for Insurance, it is my experience that he puts his commissions needs first, OVER the client's needs for a suitable and understandable product

I hope that me 22 years of experience in this Industry, Insurance and Securities licensed is of some value

(Attached File #1: s71408-1975a.pdf)
(Attached File #2: s71408-1975b.pdf)