From: James L. Culp
I am a licensed insurance professional in SC and variable product salesperson. I am writing to you concerning the suitability standard and principal review requirements pertaining to the sale of variable annuities contained in NASD proposed Rule 2821. The proposed rule's requirements appear redundant and unnecessary. I see no meaningful additional protection to consumers in this proposal. In fact, it may ultimately harm consumers by making these products less available to people who could benefit from them. To protect consumers, please enforce the existing suitability rule. I urge the SEC to disapprove the proposal.
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. This requirement appears to present a bias against these products, and will lead to constant second guessing of my advice and recommendations (based upon less first hand information than was available to me).
Again, I urge the SEC to disapprove NASD proposed Rule 2821.
Thank you for your consideration.
James L. Culp, FIC
Office: 864-322-2388 (Toll-free: 800-797-7960)