I am an Investment Advisory Representative, licensed financial representative and variable product salesperson (Series 66, 7, 6, 63, 24, life, health and variable product licensed, CFP, CLU). My focus is on helping people be prepared for retirement. I believe that because annuities can create income that cannot be outlived they are an important part of preparation for retirement. I also believe that they are at present far undersold. Rules such as NASD proposed rule 2821, in my opinion, provide no real value being duplicative of what is already in place. On the other hand, they are likely to reduce annuity sales as it will disincent sales professionals from gaining a working knowledge of these products. This will be a great disservice to our clients.

The NASD proposal is a solution in search of a problem that could ultimately harm consumers by making these products less available to people who could benefit from them. For these reasons, I urge the SEC to disapprove NASD proposed Rule 2821. Thank you for your consideration of my views on this matter.