Subject: File No. S7-14-08
From: Charles I Keller

July 30, 2008

I have never heard of anything so outrageous as the matter of EIA's being touted as a security. The Insurance industry finally comes up with something that is a real benefit to the retired community, so much so that it is hurting the brokerage industry because people are finding out they can eliminate the risk and still get a fair return on their investments, tax deferred. The SEC says so many things are wrong with the EIAs now, but watch their attitude change if they get the green light to being the only one's able to sell them, they will begin to smile once again while the industry that invented this great policy will be suffering. Just the very idea that this could happen in American is scary, I for one just pray that it doesn't, because it's just not right...The EIA is a FIXED ANNUITY WITH NONE OF THE POLICY OWNERS MONEY AT RISK IN THE MARKET, IF THEY HAVE NO MONEY IN THE MARKET HOW CAN IT BE CONSIDERED A SECURITY... C. KELLER