Subject: SR-NASD-2004-183
From: J. L Duchene, LUTCF, MS

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 am writing to you because proposed Rule 2821 duplicates requirements that are already in place. NASD rules already contain suitability requirements that apply to all sales of securities, including variable annuities.

The principal review requirements and redundant suitability standards contained in NASD proposed Rule 2821 are unnecessary, will provide no meaningful additional protection to consumers and will adversely impact my business. I urge the SEC to disapprove the proposal.

I am a licensed insurance professional and variable product salesperson. I firmly believe that people who engage in misleading sales practices should be aggressively prosecuted and subject to appropriate sanctions.

However, If regulators really want to protect consumers, appropriate enforcement of the existing suitability rule rather than adopting a new rule is the answer.

I urge the SEC to disapprove NASD proposed Rule 2821.

Thank you for your consideration of my views on this matter.


J. L Duchene, LUTCF, MS