Subject: File No. S7-14-08
From: Jeff Williams

July 15, 2008

These EIA products are not securities. They come with many guarantees and promises. One of which is the ability to link a return to a market index without the risk of loss. These are fixed annuities which have already been shown not to be securities. These fixed annuities have an indexing option to allow participation in a market index without risk of loss. They should remain under control and regulation of the insurance industry which has been providing solid protection to Americans for over 200 years.