Subject: File No. S7-14-08
From: James J. Kirlin
Affiliation: Sr. Director

July 30, 2008

Dear Sir:
Index Annuities are simply not securities. Please examine the facts and look for other methods to limit abuse's (by a small few) rather then overregulate those who have invested a lifetime into a career of helping people protect thier families and their own wealth.

States-----Insurance commissioners should oversee these matters and the Insurance industry will do a great job in protecting the public and making sure these products are properly sold.

Do not make EIA securities........they are not.

Thank you.