From: James R. Denny, III
To: Rule Comments
Sent:July 12, 2006
Subject:File Number SR-NASD-2004-183

I am a licensed insurance professional who sells varible annuity contracts. I am opposed to the proposed rule 2821. I feel that this is redundant in light of the oversight now being exercised by my company and others in this business. Those who are selling in an inappropriate fashion should be sanctioned under exisiting rules and regulations. There is no evidence that harmful sales practices are on the increase.

Discliplinary actions involving the sale of variable annuity contracts make up less than 1% of those actions taken in the past five years.

Current rules regarding supervision and suitability are sufficient to protect consumers.

Thank you, James R. Denny, III

Securities and investment advisory services offered through AXA Advisors, LLC (NY, NY 212-314-4600),member NASD, SIPC. Annuity and insurance products offered through AXA Network, LLC and its subsidiaries. James R. Denny, III, ChFC, CLU is licensed to sell insurance in the following states: District of Columbia, Maryland, North Carolina, South Carolina and Virginia; is registered to offer securities in the following states: Virginia, North Carolina, Maryland.


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