Subject: File No. S7-14-08
From: Andrew C Bozzarelli, III
Affiliation: Bozzarelli Insurance Services-29 yrs.

July 24, 2008

First of all, I don't believe "THIS EMERGENCY PROBLEM APPROACH" is justified.The SEC has had their eye on Equity Indexed Annuities from day one. You called Foul Ball as soon as the marketing of EIA's started to take off.The SEC said there was a problem with EIA's from the start. If there is, why are sales soaring to unprecedented Hieght's. The truth is that there really isn't a problem There are only a small number of complaint's in reality. I've been in the Financial Industry for 29 years.From my point of view, the products sold the most has changed since my start in 1979. The large operations of Mutual Companies Dynasty is gone, dried up. As a result, today there are more Independent Agent's or Financil Advisor's than Captive Agent's. In the 1980's,we as a group sold mostly Life Insurance Product's as Captive Agent's because thats what the big Mutual Companies wanted. Since then, mostly due to Downsizing, Agents have left the sinking boats and went Independent. One of the great things about being your own agent is the fact that you can work smarter, not harder. Accordingly, IA's found out it much more profitable selling Annuities compared to Life Insurance. Today IA's dominate the market without Big Daddy looking over our shoulders, and EIA's are not a largely regulated product. The SEC can't stand that fact at all It's as though all the training we have all had stand's for nothing In otherwords they really don't trust us Something they could not of ever forseen coming has become a giant in the savings vehicles of today, and the can't stand not having the last word The new Big daddy is Independent Marketing Offices They too operate basically without government oversite. The IMO's are taking over the Financial Industry as the majority of the IA's sell mostly EIA's currently. The day's over the over regulated Insurance Industry has all but dried up. If this rule passes, It will become only the tip of the Iceberg. What may and will probably follow may be even more paperwork. EIA's will continue, the only thing that will change is the volume of papers it takes at point of sale. The real problem with any COMPLAINT's from the public is caused by not enough fact finding on the part of the FA.Until a Complete and In depth fact finding becomes a part of every sale, nothing good comes of it. If the sale is done properly, there are no problems or complaints.