Subject: File No. SR-NASD-2004-183
From: Glen J Lutz, CFPr

August 1, 2005

I strongly support the training and more enhanced and meaningful disclosure in prospectuses, but am concerned that Propposed Rule 2821, applied in its present form, will have a substantial untintended consequence and could ultimately harm customers by making Deferred Variable Annuities less available to those who need them as legitimate tax-deferred savings, estate and retirement-planning tools.

The NASD must clearly define what is meant by long-term investment objective.

The NASD should state either the minimum standard it deems acceptable for age and amount being invested or preferably a range so we are not second guessed when we do what we believe is reasonable in light of unique client objectives.