Subject: File No. S7-14-08
From: Dennis Carpenter, CFP
Affiliation: President, International Wealth Management

July 30, 2008

Regrding S7-14-08, I respectfully request that you do NOT treat Equity Indexed Annuities as securities. First of all, there already exists numerous safeguards, forms, questionaires and authorizations, all designed for the protection of the consumer. So I would ask, what would anyone gain by this action except creating a whole new administrative nightmere of licensing and duplicative oversight that will not add any additional benefit to the consumer? In fact, I suggest that consumers will become more at risk and it will be more costly to for consumers to seek relief if a dispute does arise. This is borne out by the high cost of current securities legal action and the imbalance of verdicts from industry arbitration cases in favor of the industry. Insurance companies, on the other hand, have historically treated their policyholders w/more compassion and fairness. But if these policies are considered to be securities, then the consumers will have less security and more cost. Please vote NO. Thank you for your time, attention and consideration. God Bless.