Subject: File No. SR-NASD-2004-183
From: Kenneth Schueler
Affiliation: President and Compliance officer of an NASD member B/D

August 25, 2005

Proposed rule is too detailed on one hand and too vague on the other. All of the determined by member parts should be eliminated and stated firmly as to what the guidelines are. The rule will be next to useless without it. Is this the way the NASD is saying they are not sure on any subject. Suitability should be defined and not left as a marginal guideline subject to interpretation. To be sarcastic, if this subject matter of annuities gets any more controversial, perhaps it should be required that every potential investor should travel to and meet with NASD staff before investing in an annuity. At least this would relieve the fines imposed on B/Ds and registered reps for not being able to interpret the rule.