November 14, 2008

Subject: File No. S7-14-08

As a licensed insurance agent, registered representative and registered investment advisor, I am firmly in support of the proposed rule. I have on numerous occasions seen unsuitable EIA products sold to clients using unsuitable sales techniques. While regulation by the securities industry would certainly not solve or prevent all of these concerns, it would certainly force those in this market to become properly licensed and trained, and would likely give them pause before engaging in a commission-driven practice that would be difficult to defend.

David L. Berman, CFP, CLU