Subject: File No. S7-14-08
From: Dale A Goff, CFP

September 1, 2008

Equity Indexed Annuities require more disclosure to the client. EIA's are sold as a "guaranteed" way to invest money. Agents illustrate to the clients earnings of 12% with no loss potential. However, they don't illustrate that the EIA will probably return less than half of that.

These products are more complicated than variable annuities and therefore should be regulated in a similar manner.