Dear Sirs:

For the past 35 years, as a licensed insurance professional who also sells variable annuities I have had zero complaints or actions against me from any of my clients.

I am very concerned over the suitability standard and principal review requirements pertaining to the sale of variable annuities proposed in the NASD, Rule 2821.

I believe misleading sales practices should be prosecuted aggressively however it seems to me that Rule 2821 duplicates existing requirements already in place under general Rule 3010.

Imposing these duplications would seriously impact my practice and I strongly urge the SEC to disapprove the NASD’s proposal.

Thank you for your attention to this matter.


Curtis A. Knauss
27412 Aliso Creek Road
Aliso Viejo, CA 92656