I am a licensed insurance professional and variable product salesperson. I am writing to you regarding the suitability standard and principal review requirements pertaining to the sale of variable annuities contained in NASD proposed Rule 2821. I am aware the newest version contains many amendments to earlier versions. However, the proposed rule's requirements are still duplicating current supervision and suitability requirements that are already in place (Rule 2310 specifically). These rules are adequate to protect consumers from unscrupulous practices and simply need to be enforced. I do believe people who engage in misleading sales practices should be aggressively prosecuted. I have been told that over that last 5 years, 1 of every 200 disciplinary actions taken by the NASD involve unsuitable variable annuity sales. While each occasion of such a practice is abhorring, it is far from an industry epidemic, which is how it will appear to consumers once the new law is publicized (People believe rules are only made to solve an immediate problem, they would not realize the rule is simply duplicating rules already in existence). In addition, the requirement for review by a principal found in the proposed rule deviates in several significant ways from the general supervision requirements found in rule 3010. The requirement appears to present a bias against these products. It asks the principal to second guess my recommendations even though he/she has less first hand information than I do. I urge the SEC to disapprove the NASD proposed Rule 2821. Thank you for your consideration of my views on this matter.
Betsy O'Reilly Financial Services Rep (540)785-1786 (540)785-5816 FAX (804)221-0520 CELL
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Life insurance and annuities offered by Metropolitan Life Insurance Company, New York, NY 10166.
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