November 13, 2008

Subject: File No. S7-14-08

I would like you to know my support for the Equity-Indexed Annuity Rule. It is really pathetic to see some of my peers making so much money off of a product that is so hard to explain, much less understand. In my recent experience in attempting to show a colleague how hard it was to explain to their client the inner workings of the Allianz EIA, they were more concerned about their 9.5% commission. I also explained to this “advisor” that Allianz could change the rules of the game—how do you explain that to a client.

Please keep the rule in place and do not allow lobbyist and insurance companies dissuade you. MassMutual is one of the biggest and best rated insurance companies and they have prohibited their agents from selling these absurd products.

Thanks,

Jaime Galvan, CFP®
Partner, Spectrum Strategies, L.L.C.