Subject: File No. S7-14-08
From: Henry L Bailey

October 27, 2008

Dear Sirs I have been working in the retirement industry for about 15 years and have found no better product for a safe fixed retirement than the EIA. Client are very interested in this product versus the equities market because of risk, risk , risk. This product especially is needed with the way the market is today. It is a fixed product and therefore not an equity. I see no reason to change the guidelines for selling this product.