From: Jerry O'Reilly
Sent: July 14, 2006
Subject: File No. SR-NASD-2004-183

I am not in favor of new requirements for VA Sales because the abuses of the past are now being filtered, and would be not allowed in the current prior approval environment for 1035 exchanges. New sales would benefit from the need for enhanced, meaningful disclosure in VA product prospectuses. But recently paying out a death claim for a surviving spouse that was the amount of the original investment rather than account value (account had lost 30% of original value since 2001). Even though this was long term growth investment, the spouse received all of the original investment back within 10 days. Mutual funds and or a Self Directed brokerage account would ONLY pay account value. Only the ANNUITY could do that.

Personal Life Insurance is an entirely separate issue.

Jerry O'Reilly