Subject: File No. S7-14-08
From: Alex Kon

August 25, 2008

I am having a hard time seeing how an SEC regulation on EIA would help the protection of the seniors as it states. First lets compare the amount of fraud claims on EIA and security products, every industry has its bad apples and securities which are regulated by the SEC seem to have some sort of fraud brought public at least once very six months, and on a much larger scale compared to a client who has to pay 12% to touch their money in their EIA contract that they were not aware of. So the question is does it really provide this level of protection that is being promised. As I see it, bluntly said, its a way to stop trillions of dollars leaving the brokerage accounts over the next twenty years and going into INSURANCE products, that is what they are INSURANCE products, lets the Insurance industry control their agents and the securities control their own. Its like trying to have the FBI take regulation of police forces in certain cities where crime is high. Just doesn't work. If this is truly about protection of clients against misrepresentation and fraud then the SEC can put out educational material and courses to teach clients about EIA, not try to regulate them. We all know that sales of EIA would drop dramatically if this rule was to pass, hence less income to insurance companies which means less money in the economy, do we really need that?