Subject: S7-14-08

August 27, 2008

I APPLAUD YOUR EFFORTS TO REGULATE THE SALE OF EQUITY INDEXED ANNUITIES AS SECURITIES. I HAVE SEEN TOO MANY ABUSES OF THIS PRODUCT ESPECIALLY WITH SALES TO SENIORS. AGENTS LOVE TO TELL THE GOOD SIDE OF THE STORY BUT NOT THE DRAWBACKS. THE PRODUCTS I HAVE SEEN ARE CHARACTERIZED BY EARNINGS AT OR BELOW FIXED ANNUITY RATES AND HIGH LONG LASTING SURRENDER CHARGES.

THANK YOU.

Edward A. Hely
Wealth Management Advisor