Subject: File No. S7-14-08
From: Joseph Ho

July 15, 2008

To the SEC

Dear sir,

I have been in the securities and insurance industry for well over 20 years and I have offered securities and Equity Index Annuities to clients.

I urge you to reconsider placing EIA and Securities in the same category. EIA has many benefits including protection of principal while offering the possibility of a higher return compared to a traditional fixed annuity.
EIA is appropriate for clients that are more conservative in nature. EIA should not be treated as securities. If you place EIA in the same category as securities, the availability of EIA offered to clients will be limited since not everyone has a NASD license. Moreover, the entire financial industry will be negatively impacted since the amount of choices will be limited.

Again, I would appreciate it if you would reconsider your decision and not treat EIA as securities.