Subject: File No. S7-14-08
From: Michael C Long
Affiliation: Edwqrd Jones

October 23, 2008

This is to give my support for Proposed Rule 151a. Equity-indexed annuities are built upon the foundation of securities, just like variable annuities and mutual funds - and should be subject to the same sales disclosure regulations as variable annuities and mutual funds. The public has no idea that sales commissions on equity-indexed annuities are 2-5 times that of commissions for comparable mutual funds and variable annuities. In addition equity-indexed annuities often carry exceptionally high surrender charges for long periods of time in comparison to mutual funds and variable annuities. These commissions and surrender charges and time periods should be fully disclosed to consumers the same as other investment products, and the same licenses should be required for their sales.