From: Warren R. Horney
Sent: October 1, 2007
To: rule-comments@sec.gov
Subject: File No. S7-18-07


WFP Securities offers the following comments on the proposed rule changes:

Rule 501(a) Alternative Standard.

We concur with the alternative $750K investment standard, excluding personal residence.

Rule 504 “Restricted Securities” requirement.

We do not concur with this requirement. To comply with the time requirements of Rule 144 could cause the investor to be unable to liquidate a position for a prolonged period, potentially causing an unnecessary loss.

Rule 507 (New)

We do not concur with the requirement for a new rule defining “large accredited investors”. Differentiating between the only wealthy and the very wealthy seems unnecessary. Would there follow another category for the extremely (or obscenely) wealthy to include hedge fund managers, corporate CEOs and class action attorneys? We suggest leaving well enough alone.

Warren R. Horney
Senior Vice President