Subject: File No. S7-14-08
From: paula r competelli

July 15, 2008

As an agent of 15 years in the 403b business in Florida I am licensed to sell EIA's through LSW as well as variable annuities and mutual funds through many different companies. While I do believe EIA's should be monitored and rouge agents should be repremanded I do not believe this process needs to be done through the SEC. The state has been able to regulate these accounts and should continue to do so. They are an investment where your principle is NOT at risk, not high risk investments where clients can lose principle. EIA's offer guarantees of principle and interest credited. The only entity benefiting from EIA's being classified as a security is the Broker/Dealers. They will get a haircut on a very popular investement choice for risk adverse investors. Just because there is money to be made by B/D's doesn't mean it should be.