Subject: File No. S7-14-08
From: Joel Gooch

August 22, 2008

-The information you site is errorous and tainted. The EIA is NOT an investment as the investment can lose and an annuity cannot. The culprit you should be investigating are the crooks that sell VARIABLE ANNUITES to unsuspecting seniors that think they have guarantees. Nearly everyday I see clients that have lost huge sums in their Variable annuities. I replace them with fixed annuities that can not lose. You fail to mention that every annuity has a 100% guarantee of principal and that there is a free withdrawal of 10% each year. If more than 10% is needed there is a early withdrawal fee of a small percent of the amount OVER the 10%. I know of no way a man could buy an annuity and take all of his money out after one year that would cause him to have to sell his house. If he had a 40,000 annuity he probably got a 5% or 10% bonus the first year plus aminimum of 3.5% interest. This would amount to a value of 45,554. If he surrendered it after one year he could get 88% of his value which would have been 40075.20. There is no lway your illustration would hold up. It is erronous and should not be shown to the public. Why not take a look at VARIABLE ANNUITIES which have a current value of 20 to 30% less than the original deposit.