From: Steven C. Arndt
Nancy M. Morris, Secretary
Regrettably, all industries have a few members who operate in a manner that brings disrepute to the honest, hardworking majority. The securities industry is no exception and I, for one, welcome the SEC's efforts to weed out the undesirable participants in our business. In the case of the NASD's proposed Rule 2821, however, I believe that you have another example of unnecessary duplicative regulation that is more likely to weed out honest brokers.
Current rules on the appropriateness of securities sales apply to variable annuities and are quite adequate to protect the consumer. Enforce those rules rather than pretending that another regulatory layer will somehow inhibit the unscrupulous broker who disregards the current guidelines. It is only the honest brokers who will pay for this unnecessary addition to the rule book.
If you must tax us, please do it honestly by raising the annual fees. Then you can use those dollars to address the undesirable elements in our business. Only the bureaucrats profit from another set of disclosures and another set of deadlines to be met.
Steven C. Arndt