Subject: File No. S7-14-08
From: David J Stoller

October 21, 2008

Even though I am fully securities licensed, I feel that the Equity Indexed Annuity venue should not fall under the NASD or SEC. These are true fixed products that return a higher or lower amount of interest not unlike CD's.

I do, however, feel that the term "equity" should be removed from the terminology of these outstanding contracts. They have their place in the realm of retirement vehicles and surely are worth considering for people approching retirement or already in retirement. Simply calling them fixed index annuities would or guaranteed multi interest rates annuities would help the confusion. They are excellent for the right scenario and should not be a threat to us in the broker/dealer world.

However, they should be more readily available to securites licensed advisers to round out their offerings for clients. These products should also be avaialable for salary reduction into 401 (k)'s, 403 (b)'s, 457 deferred comp venues etc. They are not a threat to the broker/dealer community. We need to embrace them and make them an integral part of our overall advisory platforms.

Also the industry should consider a hybrid of the EIA concept in conjunction with a traditional variable annuity contract. This would be effective in lump sum situations or salary reduction into qualified plans. Why we are threatened by this contract is a mystery to me. It has it's place particularly for the older or retiring investors. It would be a benefit to our clients if we could incorporate this since many people are not suitable for the normal equities investing, no matter how conservative.

So it should remain a fixed product but be incorporated more into overall investment advisory scenarios. But drop the term equity since it is confusing. It is not an equity and this could be construed as misleading.

Just my two cents worth of opinion, since our job is to advise everyone in all scenarios.