November 14, 2008

Subject: Equity Index Annuities s7-14-08

Ladies & Gentlemen:

I am a licensed insurance agent as well as a registered representative, investment advisor representative and certified public accountant. I am also a 15 year member of the FPA. I believe that equity indexed annuities meet the definition of a security just as a corporate bond or variable annuity do. Insurance agents are marketing the products without the requisite understanding of how they work -- they are not just like fixed annuities with a market upside!

Please add my name to the list supporting recognition of EIAs as securities subject to the resulting oversite and regulation.

Thank You

Larry J. Rose, CPA/PFS, AEP