From: David Groner
Sent: August 21, 2007
Subject: File No. S7-18-07

Dear Sir:

I believe that a dollar minimum for determining investor suitability for private offerings is both unfair and ineffective. As an investment professional for 40 years I could site numerous examples of intellegent/knowledgeable indivduals without the current minimum $1 million and numerous examples of incompetent people with $1 million or $2.5 million. Where one lives in the U.S., the occupation one pursued, the wealth of one's parents, or lucky circumstances often significantly impacts one's net worth. Fear, greed and stupidity are as prevalent among individuals with wealth as many with more meager finances.

As a young man with minimal finances when I began my career, I felt discriminated against by the regulators who denied me the privilege of making private offering investments. While regulations are well meaning, they often fail to accomplish their intended goals. The net worth minimum is a perfect example of this problem.

Therefore I strongly urge you to not only not raise the minimum net worth requirement but to discontinue it all together.


John R. Hummel