From: Charles Beard
August 8, 2005
Jonathan G. Katz
Secretary, Securities and Exchange Commission Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-9309
I am a licensed insurance professional and variable product salesperson. I am writing to you because the principal review requirements and redundant suitability standards contained in NASD proposed Rule 2821 are unnecessary.
I do not think the available data supports the NASD's claims. The NASD has not statistically quantified the scope of the problem it is allegedly seeking to solve with the proposed rule. Over 95% of the comments received by the NASD regarding the proposal opposed the new rule, and the NASD has not adequately responded to the concerns raised by the commentators. For these reasons, I urge the SEC to disapprove NASD proposed Rule 2821. Thank you for your consideration of my views on this matter.