Subject: File No. S7-14-08
From: Roger Shu
Affiliation: Series 7 RR IAR

July 29, 2008

It is my professional and personal opinion that EIA or FIA type contracts are sold more often than not as "INVESTMENTS" and not as interest crediting annuity products for future income streams. It is not possible to sell these products without talking about the corresponding market index. It has been my understanding that to discuss a securities product it requires a securities license, yet an stock market index is used in the solicitation of these products. For a financial professional, licensing and adhering to Securities rules should not be an additional burden.

For those sales driven commission hunger agents, this is a disaster. They will likely complain the longest and loudest about this positive change.

Roger