I have been a licensed Insurance and Registered Representaive for the last twelve years and am writing to you because I am deeply concerned with the NASD proposed NASD Rule 2821. I understand this new rule has several amendments from earlier iterations of this proposal but I feel that this new rule is redundant to several suitability requirements that we are already bound by under NASD Rule 2310. I don't feel this new rule will benefit the clients I have agreed to protect and I do feel tht it will adversely affect my ability to help those people to the best of my ability. I urge you to permanantly dismiss this proposed (Rule 2821) with prejudice.
Please be very clear I want every single member of our proffesion who does not act in the clients best interest to be rooted out and prosecuted/ sanctioned. I do not , however, feel that the NASD has justified their need for these new Rules. The information that they publish as to problems they are seeing in the marketplace don't even support this new rule. The NASD needs to spend a little more effort on policing the industry to protect the consumer and the good name of those of us that are looking out for our clients instead of making more inefectual rules that aren't needed and are redundant furthermore, the Principal review process that is proposed does not fit with the general supervison requirements found in Rule 3010. This new requirement seems to be treating the VA as a second class investment behind Mutual Funds and Individual Securites which make up the bulk of all disiplinary action taken by the NASD. I am in a position to make determinations for my clients based upon all of the information asking someone to review a submitted document and determine the hopes, goals, dreams, concerns of a client can only lead to confusion and a less than efficient consumer expierience.
This proposal 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 in advance for your consideration of my views on this matter.