To: Nancy M. Morris
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Sent:July 12, 2006
RE:File Number SR-NASD-2004-183, Amendment Number 2

The proposed rules, as they are now, will do much greater harm than any good for the American public. This group of people is having a sufficiently difficult time saving funds for their retirement. These regulations will only make it more difficult for the public in getting to their retirement goals. It is most troubling to me that the language found in the new rules, might make it impossible for first time investors from benefit for a Variable Annuity purchase. This type of regulation borders on discrimination. How does the small investor transfer some of the risk to a large insurance company? Depriving the consumer of the guarantees now found in a VA contract would be criminal in itself. As a professional with 30 years of experience, I can tell this body that the consumer needs help saving for retirement vs. the unintended consequences of being deprived of a very good option now available. Investor experience can not be a measure for making a VA purchase. Lastly, I will not bore with how this will make it close to impossible to market VA contracts based on additional time and expenses that no one can absorb.

Thank You,

Armand Minasian, CFP

Armand Minasian, CFP 1255 Post St., Suite 501 San Francisco, CA 94109-6715 Phone 415-776-9945 Fax 415-776-9948

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