From: Royal Lea
Sent: August 4, 2005
To: rule-comments@sec.gov
Subject: File No. SR-NASD-2004-183

David Fickett
5936 Mira Hermosa
El Paso, TX 79912

August 4, 2005

Jonathan G. Katz
Secretary, Securities and Exchange Commission Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-9309

Jonathan Katz:

I have been an insurance professional for 42 years, a CLU and ChFC, a life member of the MDRT, a member of the Society of Financial Services Professionals, and a registered representative since 1969. I subscribe to the highest standards of integrity and professionalism in the insurance business and securities. I deplore dishonesty and self serving in our business as much as anyone. However, I believe that the proposed Rule 2821is inappropriate for the following reasons: 1. Existing procedures are adequate to regulate the sale of deferred variabe annuities. 2.
Special rules for certain products is unwise, counter-productive, and can become abusive in themselves. 3. The public will be denied the opportunity to invest in variable annuities, not because they are flawed, but because representatives and their broker-dealers will determine the hassle isn't worth doing the right thing for the customer. Just the opposite effect that the SEC is seeking.

For these reasons, I urge the SEC to disapprove NASD proposed Rule 2821.
Thank you for your consideration of my views on this matter.

Sincerely,

David M. Fickett, CLU, ChFC
915 496-8475