From: Dave Spellman
Sent: July 18, 2006
To: rule-comments@sec.gov
Subject: File No. SR-NASD-2004-183


Dear Ms. Morris:

I am an insurance and financial professional actively involved with my clients who own Variable Annuities. It is my opinion that the proposed rule 2821 is overkill.

While I understand there may be unscrupulous individuals in the marketplace who engage in bad sales practices, I believe there are more than enough rules and regulations on the books now to deal with them.

More rules don't solve anything. I suggest greater degrees of education and professionalism should be required of both Broker Dealers and their Registered Representatives, as well as enforcement of existing rules.

And here in the Maine marketplace, I would suggest there are extremely few complaints from consumers -- and those that do occur are pursued aggressively by State, Industry and Federal regulators. Trying to achieve a cure where there really isn't a problem will only require all of us to spend more time and paperwork to affect no positive impact.

Thank you kindly for your consideration.

Dave Spellman, President
Pratt Financial Group, Inc.
969 Main Street PO Box 439
Westbrook, Maine 04098-0439

National Committeeperson & Government Relations Chair,
National Association of Insurance & Financial Advisors-Maine (NAIFA-ME)
Qualifying & Life Member, Million Dollar Round Table