The Securities Industry Association (SIA)* provides comments the Securities and Exchange Commission (SEC) on an amendment to a proposed new National Association of Securities Dealers, Inc. (NASD) Rule 2821 that would govern deferred variable annuity sales practices and supervisory procedures, Release No. 34-52046A; File No. SR-NASD-2004-183.  SIA believes the proposal as drafted is duplicative, expensive and potentially counterproductive to the objective that investors be provided meaningful information regarding the purchase of a deferred variable annuity.

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