Subject: SR-NASD-2004-183
From: Ken Smith
Affiliation:

August 5, 2005

Jonathan G. Katz, Secretary,
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-9309

Jonathan Katz:

I am a licensed insurance professional and Series 7,24, and 65 securies licensed. I am writing to you because the principal review requirements and redundant suitability standards contained in NASD proposed Rule 2821 are unnecessary, will provide no meaningful additional protection to consumers and will adversely impact my business. I urge the SEC to disapprove the proposal.

In plain English, there are more than enough safeguards in place to protect the public. The bigger deterrent to unethical practices is if current law violators would be more aggressively prossecuted.

Finally, it seems to me that the NASD needs to validate that there is a real problem that this action will really solve. The NASD has not statistically quantified the scope of the problem it is allegedly seeking to solve with the proposed rule. Furthermore, over 95% of the comments received by the NASD regarding the proposal opposed the new rule, and the NASD has not adequately responded to the concerns raised by the vast majority of commentators. For these reasons, I urge the SEC to disapprove NASD proposed Rule 2821. Thank you for your consideration of my views on this matter.

Sincerely,

Ken Smith