Subject: EIA's
Date:    8/27/97 4:00 PM
     
     
Dear Secetary Katz;
     
Being both a licensed insurance agent and registered representative series 7.
 I feel EIAs should be regulated as an annuity.  
     
The floor guarantee crediting rate should satisify the Safe Harbor rule.
 Basically there is no market risk of capital by the annuitant.  The insurer
is only using the index as a guide as to intrest crediting.
     
Robert Glascock C.L.U.