November 13, 2008

Subject: S7-14-08 comments on EIA

I have been a financial advisor for 17 years, and am also have been licensed as an insurance agent for the same period. I support the rule. There are too many non securities licensed insurance agents running around selling these things as investments to little old ladies. Neither the agents nor the clients understand them. The products, sales practices, and marketing methods need uniform oversight that can only be properly implemented on a national scale.

Howard D. Richards, CFP®
Certified Financial Planner™ Professional
Cambridge Investment Research, Inc.