From: Gerald W. Hall
Sent: June 30, 2006
Subject: File No. SR-NASD-2004-183

Dear Nancy Morris, Secretary, SEC: this email is in response to the above mentioned subject. I understand the SEC does everything in its power to protect the investor, and I agree that you should. However, the amount of disclosure and paperwork needed to complete an annuity application is absolutely unnecessary and ridiculous! and now you want to make it worse!!! You cannot tell me that VA's with all the NEW living benefits and old death benefits do not have their place in the industry. they most certainly do have their place, especially with the continual freezing of pensions and the social security uncertainty. these products have a great place in the industry and they are only going to become more popular as more and more people are looking for GUARANTEES! people want a guaranteed income for life without having to worry about the market and econcomy everyday for the rest of their Golden years. VA's are another investment option, just like mutual funds or SMA's. why should their be any additional disclosures at all? if the Financial Advisor is ethical and doing his job by doing what's right for the client in finding them a suitable investment that helps them accomplish their financial goals then why make it harder, more cumbersome, and more costly and time consuming for the advisor and more confusing and frustrating to the client? this is the biggest waste of time and money for the SEC. the FA should have the right to invest his clients assets in any product or investment that is suitable for the client. whether investing in SMA's, mutual funds, fee-based accts, UIT's, ETF's or any type of annuity, the process should be all the same and equally as easy. the extra time, paperwork, costs, disclosures and confusion is just an absolute waste of time for everyone. If an Financial Advisor is unethical and not making suitable investments on behalf of his clients then they should be fined, have their registrations pullled or whatever punishment is deserved. the rest of us ethical FA's should not have to be punished for the unethical ones. why does the SEC and NASD insist on punishing the good people because a handful of FA's are unethical. Punish the bad people not the good. The only people who will suffer because of all this nonsense are the quality FA's who try to do the right thing and their clients who will not be offered an annuity because of all the extra work involved...even if it is absolutely the best solution for that client. the unethical advisors will only find away around doing what the SEC requires anyway. Everyone will lose if the SEC continues to allow all of this additional work to buy annuities. there are a ton of advisors that do not disclose to their clients that they have a choice on A, B and C share classes on mutual fund purchases. the FA decides to put them in whatever share class he feels like. others are churning client accts with stock and mutual fund trades in order to generate commissions and you are worried about annuity sales (that are GUARANTEED to the client). IT IS THE ADVISOR THAT'S THE PROBLEM, NOT THE PRODUCT OR INVESTMENT! come down harder on unethical advisors and simplify the procedures for the rest of us ethical people.

Gerald W. Hall
Branch Manager / Financial Advisor
Raymond James Financial Services, Inc.
33 Church Street
Fredonia, NY 14063
716-672-7801 Fax