To The Editor:> In our recent filing with the National Association of Securities Dealers on its proposed variable annuity suitability and supervisor rule, ACLI says nothing about NASD’s proposed training procedures, as reported in “ACLI Challenges Proposed VA Suitability Rule,” Sept. 26. Also, our concerns with the proposal do not really relate to holding supervisors more directly responsible for inappropriate VA sales.

Instead, our position is that current suitability and supervision rules provide significant, uniform standards assuring appropriate market conduct. We recommended that the NASD should require broker-dealers to strongly encourage consumers to carefully read the synopsis and fee table in the prospectus. Indeed, the most effective solution to inappropriate VA sales is strong enforcement of existing suitability and supervision standards.

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Carl Wilkerson

American Council of Life Insurers

Washington, D.C.

To The Editor:

I am not often moved to write to periodicals in response to an article. However, Jack Bobo’s comments in “We Are All That Some People Have” (Sept. 12) really hit home. I deal primarily in the small group market. Mr. Bobo is dead on when he recalls the words of Jim Krueger that we are the ones our clients call when they need help. His piece also reminded me that unless we make a strong effort to the contrary, we are mostly invisible until and unless the client has a problem. Sadly, we are not regarded in the same light as, say, the accountant or the attorney, who the owner of the company may see once a year, if that, even though we (the broker) may talk to him (the owner) several times or more a year. We are simply not seen as having the same “clout.” Perception is reality. In fact, as Mr. Bobo’s piece points out, we make a huge difference in the lives of our clients. It’s too bad this kind of “eureka moment” can’t be induced in everyone.

Joseph Sperling, JD, CLTC

Kelly Benefit Strategies

Rockville, Md.