Subject: File No. SR-NASD-2004-183
From: Raymond O Streu, CFP
Affiliation: Board Chairman, Asset Planning Group, Inc.

August 10, 2005

Please take care not to throw the baby out with the bath water when you act on the current NASD proposed changes regarding Variable Annuity contracts sales rules.

I agree there has been abuse selling VA contracts by uniformed OR averious sales persons in the past. This can be corrected with proper training and control either by the insurance companies,the broker dealers or a combination of both.

If we are not careful with some of rulings as proposed, the results could surely limit the use of VAs in places where the product has definite advantages. For example, putting an age limit was proper with previous contracts, say 5 years ago. Today, many VA carriers in our insurance industry have changed the structure of the contracts that eliminates many of the previous problems. For example, it is possible to give a 70 year-old investor riders in their that allow the annuity cash flow go not only to the spouse, but to the children.

I agree there are abuses, but please do not curb the structure of the contracts or the profile of the purchaser. This unfairly penalizes investors in many cases by preventing the use of the features. The other choice is to ensure that there will be no inflation in the United States. If the Congress and the Adminstration can stop inflation and pass fair tax laws, then we do not need to worry about using the features and benefits found in VAs.

I fervently agree those agents/registered representattives that abuse the use of Variable Contracts should be held accountable.

PLEASE DO NOT PASS THE RULINGS AS PROPOSED. THE ULTIMATE RESULT WILL TAKE AWAY INVESTMENT OPTIONS TO THE OLDER INVESTORS THAT COULD NEED MANY OF THE FEATURES OF THE NEWER POLICIES THAT ARE NOW BEING MADE AVAILABLE.