From: Frank Luczak
August 5, 2005
Jonathan G. Katz
I am a licensed insurance and securities representatve. I am writing in regard to the NASD proposed Rule 2821. I feel that the restrictions that they are proposing are redundant and will retrict my ability to serve my clients efficiently.
Rather than further retrict my ability to serve my clients with integrity I would suggest that the regulatory bodies should enforcethe regulations that are already in place. Further they can prosecute the few individuals who break the current rules and regulations. The same suitability rules that apply to mutual funds also apply to variable annuities, and quality agents and companies adhere to these regulations.
These proposed requirements single out a particular product in an apparently biased manor. We as the agent have a more intimant relationship with our clients and good agents are going to keep the best interest of our clients as a priority.
I do not believe that the available data supports the indicated level of concern the NASD has claimed. Further singling out an individual product for more stringent regulation could create many more problems than it solves.
I also feel that these proposed regulations would be an infringement on my ablities to serve my clients and adversely impact my ability to conduct business.