Subject: File No. S7-14-08
From: William A. Evans, III

October 14, 2008

I became securities licensed back in 1986. I held multiple security licenses for over 20 years. A few years back I started working more with seniors. It didn't make sense to put their money at risk in the stock market, especially as they got older. I dropped my securities licenses because I didn't want to be tempted to put my clients money at risk. I found equity indexed annuities to be a safe place to put seniors, with the opportunity to protect against inflation. I'm afraid that Sec 151A will have an unintended consequence of putting more seniors at risk. Requiring agents to be securities licensed will just put more seniors savings in the stock market.. The last several years I've seen suitability forms, from different insurance companies, become overly restrictive. This market is already heavily regulated. Adding another layer of regulation will only create the opposite of it's intention.