From: Thomas G. Krach
To: Rule Comments
Sent:July 13, 2006
Subject:File Number SR-NASD-2004-183

Looking at the new proposed rules changes on Variable Annuities, In my 23 year career over seeing thousands of sales, my biggest concern has always been the garbage fixed annuities sold by agents to seniors by Allianz and Midland to name a few that have outrageous surrender charges, sucker first year rates that lure uneducated consumers in, and the 8,10 ,12% commissions paid. I donít see the Variable Sales being a problem due to the strict compliance by the major firms and records that must be complete. The point of sale person is best to understand the clients situation as they should do complete discovery before making the sale. Consumers have different needs, understanding of the market and risk factors that can best be handled at point of sale.

Thomas G. Krach