Subject: File No. S7-14-08
From: francis x mckeown
Affiliation: SHK...school of hard knocks

August 4, 2008

I've been in the financial services business just over 50yrs and this SEC effort is, without doubt, the most
ridiculous, idiotic, disingenuous attempt to gain control of an entire market segment.

When the EIA came upon the scene,what really appealed to me
is that the annuitant can share in the market upside without ANY DOWNSIDE RISK NO MARKET RISK

The real problem as I see it is that SUITABILITY is not policed enough or enforced. But in no way is an EIA a
security.

In closing, I would suggest that the SEC has plenty on its
plate without attempting to rape the EIA market. Stay in
your own backyard...SEC...the grass is not greener on the EIA side of the fence May the fence endure forever

Francis X. McKeown