Subject: File No. S7-14-08
From: Christopher Scott

July 16, 2008

If you make EIA come under SEC rules, the products will essentially be nothing more than variable annuities. Then there will be no need to have them.

Clients like EIA due to the fact they money is protected from market loss but they can participate in the good times as well for very low if any cost. The days of no management fees and no basis points will be gone with EIA's since it will cost insurance companies thousands and thousands more dollars to administer these products that wouldn't be and is not even now necessary.

You more or less will kill the EIA. Which I am sure that will make you happy since VA's have been getting their butts kicked from them. We know you want more control and can't stand to lose. All you will be doing is hurting the customer that has a low risk tolerance from ever making good interest.

Congratulations.