Subject: File No. S7-14-08
From: James W. Neal

July 7, 2008

To Whom it May Concern:

I have several concerns/questions with the SEC considering the requiring of a Security License for the marketing of Equity Indexed Annuities. I share the concern, as do all ethical sales representatives, of those who lack integrity and use these products as an opportunity to steer "seniors" into programs that are not suitable for their particular needs or into policies that pay the highest commission.

That being said it appears as though there might be an over-reaction to the aforementioned challenges that would in fact impose undo hardships and penalties to the thousands of integrity driven sales representatives.

My concerns would be
1. Is the SEC over-reaching there authority and
2. Does the SEC in fact have jurisdiction in this matter
3. Is the SEC in reality reacting to pressure being
placed on them by "Wall Street" and its Broker/Dealers
to take this action because of there fear of
competition in the market place.
4. If these products are re-labeled as Securities there
will corresponding fees added to the contracts
resulting in a less favorable product for the CLIENT.
5. These products have no market risk for loss of
principle and therefore really do not qualify to be
labled and "lumped" in with other Security products.

Finally be it known that I will be joining with hundreds if not thousands of other representatives in a class action suit to sue the SEC over this matter.

I trust that you will consider fully all the ramifications of this intended action and find that it is not necessary nor needed in this particular instance.

Cordially yours,

James W. Neal, CEO
Gold Cup Financial, Inc.