Subject: File # S7-14-08, EIA

August 27, 2008

May I point out that every abuse I have worked on or received information from one of my clients has been done by someone with a Securities license. This rule will not rectify scare tactics or suitability problems by brokers or registered representatives with a series 6 or 7 license. Part of the problem is the insurance contract put out by the insurance company and approved by the states. You might think you will have more control over who sells EIA or be able to hand out harsher punishment or be better at removal of a sales person from the predatory practice that has occurred. You will not. If an insurance company who sells in a state with strong laws and good enforcement is inadequate, you will not succeed until EIA insurance products with 15 or 20 year surrender periods and surrender charges exceeding 9% are changed to 6 or 10 years surrender period causing commissions to decline and the 70 year old is no longer screwed by those with a security licenses. You can’t handle the unsuitable sales practice now, how do you expect to improve upon your past? When a broker takes advantage of a senior it causes problems for all ethical, licensed sales people. Try ending seminar selling with free meals that attract seniors. Work with the state Insurance Commissioners to insure seminar scripts are being reviewed and monitored by compliance. Have every seminar sales presentation video taped and submitted to compliance. Cause the use of misleading insurance contract terminology such as “100% participation” stricken. It is a joke, 100% of what? If an insurance company wants this problem corrected they and they alone can do it.

Sincerely,

Hollis O. Inglett, Jr