Subject: File No. S7-14-08
From: Francis X McKeown, SHK
Affiliation: School of Hard Knocks

August 21, 2008

Being almost 79 years old and having benn in the business
for 49yrs,here,s how I see

A totally misdirected effort. the SEC memo seems focused on the suitability problem,which is serious and always hovers over any product sales. Every product for sale has
suitability problems. Therefore: We should increase the
policing of suitability...and the SEC should have nothing
to do with EIAS...because they are NOT securities even
though the SEC is trying to make them exactly that There
is absolutely NO RISK. The EIA shares in the upside of
the market and the account balance holds when the market
falls. Very simple

Everyone should devote more effort to the suitability
problem in securities,annuities,life insurance, etc.

Please stop wasting time,effort and money on frivolities

Thank you