Subject: File No. S7-14-08
From: Harold Clark Colborn, Jr., ChFC, CLU
Affiliation: Life Member MDRT

July 30, 2008

The SEC has ruled on EIAs. Nothing has changed except that the public wants less risk and more insured EIAs. Perhaps the insurance commissions should rethink surrender charge periods and/or amounts (as should the banking industry with their CDs), but the insurance commissions seem to be doing a better job of regulating insurance people than FINRA does in regulating stock brokers. The ratio of complaints about stock bkrs to ins. people is about 4 to 1.

Again, nothing has changed with the product except billions are going into it. So is it just that FINRA is losing money that is making the SEC, all of a sudden, say "I guess we were wrong ... it is a security ... even though we originally said it definately was not"