Subject: File No. S7-14-08
From: Michael E Gibbs , Sr
Affiliation: CEO, M GIBBS CO., INC

October 29, 2008

There is NO risk to the client by using EIA. Product loaded with fixed guarantees never to lose principal and fixed returns. Product is not a security. Fixed annuity with option to earn additional interest based on performance of Indusrty Indexes which are not securities only measuring tools to measure performance of the total financial markets.

This is only another way to perserve the investments banks position in the marketplace. They are loosing money because people are taking their monies out of the market and placing them in EIA account. Why, because they are safe and insured. Your money is SAFE. The insurance company takes the risk and not the customer.

Insurance companies are already heavily regulated for the protection of its members. As we have seen in recent days, the securities (Investment Banks) market was self regulated and it did not work.