Subject: File No. S7-14-08
From: ernest caponegro
Affiliation: CEO EMC Insurance Agency Financial Services LLC

August 25, 2008

AN EIA is not a security , its not an equity , its not debt, its a Life Insurance Instrument that pays its rate of return based on an outside index,

Policy holders are not at risk of losing principal.

This is nothing more than an SEC/FINRA power grab, its all about money.

EIA dont flucuate in value, but US treasury Bonds, Mutual Funds and Stocks all do.

So placing some money with an Insurance Company via an EIA, is a good deal for the income oriented market who wants a better rate of return without the risk.

Has anyone ever lost a dollar of principal? NO,

So forget the rule, give back to the insurance community what they cover. and let the SEC and FINRA police the brokerage community for bad stocks, investment banks, and aution rate preferreds.