Subject: File No. S7-14-08
From: Elmer P Brinkman, CLU
Affiliation: NAIFA

August 4, 2008

Ladies and Gentlemen of the SEC:

I write to object to Equity Indexed Annuities being categorized as securities. My understanding is that there is no money that goes to an equity indexed product that is exposed to the risk of the equities markets, or at least to the extent that loss of principal is possible.

With this being the case, the proposal to make these products securities makes no sense whatsoever. Those of us who hold licesenses to market these products can explain how they work to the consuming public without the added layer of a securities license to do so.