Subject: File No. S7-14-08
From: John C Melton, Sr.
Affiliation: Legal and Compliance Director-Coastal Securities

July 23, 2008

Better late than never. My first experience with Equity Indexed Annuities(EIA) involved a presentation made to my mother. I was mortified to discover that the photo copied one-page "information sheet" was the sum total of the "disclosure" that she might receive should she have elected to purchase this product. I have not tracked performance of these products, but one thing is certain, yield-to-broker was extraodinarily high. When insurance companies create a product that is to be marketed as a substitute for a security and retains many of the characteristics of a security, they should be prepared to have that product regulated as such.

Expanded disclosure and federal regulation of this product is long overdue.