From: E. Michael Gillmor
To: Rule Comments
Sent:July 13, 2006
Subject:File Number SR-NASD-2004-183

To Whom It May Concern:

In my 11 years in the field, I have found that the majority of sales made in the Variable Annuity market have met suitability requirements. Most if not all insurance companies have a review unit that approves the sale of Variable Annuities. Review units will check age, assets, source of funds (any penalty for early withdraw) and risk tolerance among other things to make sure that the sale is suitable for each client. In my opinion, the majority of questionable sales practices have taken place in the Indexed Annuity market. Many agents are selling Indexed Annuities with extended surrender charges where the only option to withdraw 100% of the complete value of the contract is to annuitize. In addition, most clients do not understand how the indexed annuities work and are generally sold because of large bonuses (often sold as the reason it makes sense to take penalties for early withdraw). I think that the SEC would do the public an incredible amount of good by developing stronger regulations on the sales of Indexed Annuities. The sale of Variable Annuities already has internal controls and suitability requirements (licensing, firm element training, etc.), but any life licensed agent can present and sell an Indexed Annuity without any knowledge or training about the market and without the need for a securities licenses.

E. Michael Gillmor
Financial Services Professional
New York Life Insurance Company
6000 Lombardo Center
Suite 300
Seven Hills, OH 44131

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