Subject: File No. SR-NASD-2004-183
From: David H Davis , CLU,ChFC,CSA
Affiliation: Financial Advisor

August 8, 2005

The later versions of the DVA offered through major DVA providers allow owners ways to better diversify their investments to have affordable health, to have automatic rebalancing for both the qualified and non-qualified accounts,to allow more ways to pass on remainder to heirs in a manner they choose. Many times less expensive than using trust. As for the long time horizon, the surrender charges on the contracts we use are from one to four years at most. The great majority of reps use a DVA for the best interest of their clients. The problems are from the minority. It is virtually impossible to regulate against the minority of dishonest reps. Regardless of the rules, the dishonest rep will still be a problem. Constantly increasing the reporting and disclosure requirements does not effect the dishonest person, only the people who are trying to do the best for their clients.