Subject: File No. S7-14-08
From: Joseph Ho
Affiliation: MPA NASD7

October 31, 2008

Gentlemen,

I have been in the financial industry for well over 20 years. Currently, a large portion of my clients have indexed annuities. I am familiar with how an EIA works and I think it should not under the jurisdiction of the SEC. I think there should be more continual education requirements for someone that markets EIA. However, I believe it should not be considered as securities due to the nature of the contract. I urge you to reconsider your decision and to keep EIA as an insurance annuity product and not as an investment.

Thank you,

Joseph Ho