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U.S. Securities and Exchange Commission

The following Letter Type D, or variations thereof, was submitted by individuals or entities.

Letter Type D:

I am a licensed insurance professional. I am writing to you concerning the suitability standard and principal review requirements pertaining to the sale of variable annuitie4s contained in NASD proposed Rule 2821. This proposed rule is both redundant and unnecessary and will provide no meaningful protection to consumers and will adversely impact my business instead. I urge the SEC to disapprove this proposal.

I am not against prosecuting people who engage in misleading sales tactics, but this issue is already coverd by the NASD (i.e.- Rule 2310)... the addition of proposed rule 2821 almost seems like an attack on our business rather than concern for the public. If a concern for the public is the issue, then just enforce the rules that are already in place!

Lets not forget that Unsuitable variable annuity sales consisted of less then .5% of NASD disciplinary actions! only HALF of a percent! There is no need for proposed rule 2821.

I urge the SEC to disapprove the NASD proposed Rule 2821 as it seems to present a bias against products which ultimately are very good for consumers.

Thank you for your time and consideration.


Modified: 07/31/2006