Subject: File No. SR-NASD-2004-183
From: Michael J Vitalbo

August 3, 2005

The issues at hand concerning the sale of Variable Annuities should contain a thoughtful process to intent of the individual client. Knowing the client is the primary factor in making a decision as to the purchase of this product. In order to properly determine the need of the client a fact-finding session along with discussion as to the time horizon and optional rider capability and its application are crucial.

The cookie-cut regulation does not address the needs and wants of the individual client. No personal, hands on approach can be understood by the black and white of written regulation.

The careful understanding and diligence with each client cannot be replaced or understood by this type of regulation.