Subject: File No. S7-14-08
From: John P Duncan
Affiliation: Financial Advisor

July 30, 2008

I believe EIAs should definately be classed as securities because most of the insurance agents are "posing" as financial advisors. They twist facts about securities to make EIAs the only viable option. I am not opposed to EIAs and use them regulary when part of a complete plan with clients. Futher, where is most of the money that goes into EIAs coming from? It is coming from securities. How can someone with no securities licensing discuss securtities (i.e. what to buy and sell). I am looking forward to all the non securities licensed insurance agents who use fear and manipulation instead of real planning to go away. Thank You.