The Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on Amendment No. 2 to proposed National Association of Securities Dealers (NASD) Rule 2821 governing deferred variable annuity (DVA) sales practices and supervisory procedures.  SIA believes the rule proposal contains certain provisions that are vague and do not meaningfully contribute to the overall objective of investor protection in recommended transactions in DVAs, Release No. 34-52046A; File No. SR-NASD-2004-183.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.