From: Melody Juge
August 11, 2005
Jonathan G. Katz
RE: NASD proposed Rule 2821
I am a stockbroker and a variable product salesperson.
The principal review requirements and redundant suitability standards contained in NASD proposed Rule 2821 will provide no meaningful additional protection to consumers and will adversely impact my business. I urge the SEC to disapprove the proposal.
People who engage in misleading sales practices should be aggressively prosecuted and subject to appropriate sanctions.
To truly protect the consumer strict enforcement of the current suitability rule would be a better solution.
Rule 2821 duplicates requirements that are already in place.
There appears to be bias against theseproducts in this proposed rule
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.