Comments on NASD Notice to Members 04-45

Dear Ms. Barbara Sweeney:
I am a licensed insurance professional and variable product salesperson and in favor of the proposed rule. I am writing to you because the proposed rule would help to minimize any confusion that the consumer may have when purchasing an annuity.

I firmly believe that people who engage in misleading sales practices should be aggressively prosecuted and subject to meaningful sanctions. 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 be helpfull in summerizing specific information already found in the prospectus and reduce the likelihood that consumers will not be fully informed about the product they are purchasing.


One other thing I would add, please make any risk disclosure document as short and clearly understandable for the consumer. Also, I would suggest making it part of the annuity application.




Michael Cano
214 Carnegie Center, Suite 110
Princeton, NJ 08540