November 17, 2008

Subject: File No. S7-14-08

I have been a Financial Planner / Investment Advisor for over 12 years. I own and operate my own Registered Investment Advisory firm. I have an extensive background in investments and insurance. In that time I have built spreadsheets to calculate the risk/reward of many types of products. One of the worst products in my opinion has been the "Equity Indexed Annuity."

In my calculations, the investor never wins. It is insurance company hocus pocus, and most of the equity indexed annuities are sold through sub-par insurance companies. Companies that I would never use, companies I would NEVER trust. This is probably one of the worst insurance products I’ve ever seen. And the thought that they are being sold by people with a lack of investment knowledge is despicable.

I urge the SEC to make these products available at a minimum to advisers that have at least a Series 6 or Series 7 license.

I urge the SEC to completely throw out these ridiculous products. To stop them now. They benefit no one but the insurance companies and the agents that sell them.

Laurence E Menna
Financial Planner, RJFS