From: Barry Levine
Sent: July 13, 2006
Subject: File No. SR-NASD-2004-183

To: Nancy Morris, Secretary:

I am a registered rep voicing my disapproval of this proposal. The reps who are trying to do the right thing for their clients should not be punished.

No other product like variable annuities can protect the lifestyle of so many; lifetime guarantees are so important now, given the fact that we are living so much longer. How great it would have been if this product had been around before March 10, 2000, the start of the deep market correction. How many retirees would not have to go back to work if this program existed?

Yes, those who deceive their clients should be punished. That is why the rules exist any way. Their are many safeguards already built in. We have the clients sign and initial in many places so they understand what this program is about. Our OSJ reviews each file one at a time and then the broker dealer reviews it. No other industry is as heavily regulated as ours. Adding more layers would only have clients second guess our ability and they would not trust anyone in the industry.

I urge you not to proceed with this new legislation.


Barry Levine, CLU, ChFC, LUTCF