Comments on NASD Notice to Members 04-45

Dear Ms. Barbara Sweeney:
I am a licensed insurance professional and variable product salesperson. I am writing to you because the redundant disclosure and suitability standards contained in NASD's proposal to impose specific suitability and disclosure requirements on the sale of variable annuities are unnecessary, will provide no meaningful protection to consumers and will impact my business. I urge you to withdraw the proposal.

 

Your proposal would duplicate requirements that are already in place. If regulators really want to protect consumers, appropriate enforcement of the existing suitability rule rather than adopting a new rule is the answer. Variable annuity prospectuses, which are already reviewed by the SEC, already discuss the fees, risks and expenses associated with variable annuities. Requiring a separate "risk disclosure document" would duplicate information already found in the prospectus and reduce the likelihood that consumers will read the most important source of information on the product -- the prospectus.

I urge NASD withdraw the proposed rule. Thank you.

 

Sincerely,

Gina DiMarzio
1502 W Cherry St
Robinson, IL 62454