I am a licensed insurance professional and variable product financial advisor. I am writing to you concerning the suitability standard and principal review requirements pertaining to the sale of variable annuities contained in NASD proposed Rule 2821. Although the latest NASD proposal includes several amendments made to earlier versions of the proposal, the proposed rule's requirements are redundant, unnecessary, will provide no meaningful additional protection to consumers and will adversely impact my business. I urge the SEC to disapprove the proposal.

It appears that the new ruling is superfilous. I recommend that the NASD concentrate its efforts on enforcing the current regulations and not add to the burden already fplaced upon investment and financial advisors, who conduct themselves in an ethical manner.

Currently it is incumbent upon me to explain in great detail the advantages and disadvantages of variable annuity products to prospects who may be interested in this savings or retirement vehicle. The new ruling is an unnecessary addition to the process of full disclosure.

Thank you for your consideration in this matter.