From: Gregory A. Wittland
Sent: July 17, 2006
Subject: File No. SR-NASD-2004-183

Nancy M. Morris
Securities and Exchange Commission

Dear Ms. Morris:

I am writing to express my concerns regarding proposed NASD Rule 2821. As a registered reprensentative with Transamerica Financial Advisors for the past 11 years I have used variable annuities when appropriate for my clients. My concerns over the new proposed ruling is that it will generate unnecessary burdens on myself and my broker dealer while at the same time giving no addtional safeguards for the client. We already have in place Rule 2310 for suitability of investments. Lets take an aggressive approach in identifying and punishing the few representatives that are taking advantage of their clients instead of penalizing the vast majority of registered representatives that are attempting to be compliant in this area. It is my understanding that that one half of one percent of the NASD disciplinary actions over the last five years have been due to unsuitable variable annuity transactions.

Thank you

Gregory A Wittland, CFP(R)
1022 Maine St
Quincy, IL 62301