Subject: File No. S7-14-08
From: Donald S Loveless, CFA CFP
Affiliation: CCO, Independent Investors Inc (RIA)

August 11, 2008

I support regulating EIAs as securities. Several years back when I found out they were not regulated as securities I was very surprised.

I also am oppposed to extending the comment period past September 10.

I am a practicing Investment Advisor- 25 years. In my discussions with clients and potential clients that have either been sold an EIA or the sale to them was attempted it was clear to me in 100% of the cases the client had no idea what they were buying or thinking of buying. In several discussions with the agents selling the product again, in all cases, it was clear to me they did not understand the product.

Further, intuitively, a product 'linked' to a security index and the return on that index should be regulated like a security.

Thank you.