Subject: File No. S7-14-08
From: Lynn E Williams
Affiliation: NAILBA Member Agency

October 20, 2008

Currently broker dealers are required to supervise the sale of EIA products with the same degree of accountability as any other securities based product while non securities licensed professionals have the ability to sell EIA's with no oversight.

This inconsistency in regulatory oversight is not serving the public very well. I believe the current proposal to require any professional selling an EIA product to hold a securities license is the correct solution.

While it may limit the number of products available to consumers in the short term I believe consumers will be better served in the long run.

Lynn E. Williams, CLU, ChFC