From: Frank Lavin
To: Rule Comments
Sent:July 13, 2006
Subject:File Number SR-NASD-2004-183

To whom it may concern:

I oppose the prososal put forth by the NASD for an additional regulatory requirement for the sale of variable annuities. It is my understanding that unsuitable variable annuity sales account for less than .5% of the NASD's disciplianry actions over the last five years. This proposal clearly is unwarranted and shows bias against the use fo these products at a specific point in history where theire usefulness and need is greater than ever, in my opinion.

Let the NASD spend it's time adding additional regulation to areas of concern vis a vis historical sales and product misuse and abuse.

Very truly yours,

Frank Lavin
AXA Advisors,
88 Kearny Street 20th Floor,
San Francisco, CA. 94108


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