Subject: File No. S7-25-06
From: David L. Spurr
Affiliation: Merrill Lynch Global Private Client, Investment Advisor

January 27, 2007

First, I would like to state that this opinion is my own personal opinion and not the opinion of any organization that I work for or any organization that I'm affiliated with.

It is my belief that Hedge Funds should be made available to all investors, not just the wealthy. It is my opinion that Net Worth should not be the criteria which determines eligibility for investments, such as Hedge Funds.

In the past, the presumption was made that an investor's net worth was the best determinant of his/her level of sophistication or knowledge about investments and the associated risks of those investments. This is not true.

There are many High Net Worth individuals that do not have a clear understanding of the specific risks associated with various investment vehicles, such as Hedge Funds.

Perhaps individual investors should be required to watch a short video or podcast, which will explain the risks associated with Hedge Fund Investing.

There could be a short test/quiz after the podcast or video. The process would require an investor to achieve a passing grade. Once the investor has received a passing grade, a specific ID# could be issued to the investor, that he would reference on all hedge fund transactions.

This ID number will need to be provided to the investment advisor at the time an account is opened, or at the point the investor begins to inquire about the possibility of investing in hedge funds.

The ID number would indicate that the investor has the required minimum level of knowledge, necessary to consult an advisor about Hedge Fund investing.

Limiting Hedge Fund Investment only to wealthy individuals is discriminatory. Investment advisors should be used to explain the associated risks of hedge funds to clients.

The beauty of the "Laissez Faire" capitalist system is that funds should flow, opportunistically, to the best investments available. Investors should be free to decide where they choose to allocate capital. The government should not restrict individuals from investing in Hedge Funds.

Ideally, investors should allocate capital to investment vehicles that provide appropriate risk adjusted returns, consistent with their stated investment objectives.

The Advisor should heve the flexibility to use investment vehicles that the Advisor deems appropriate.

Many Hedgefund managers have been sucessful employing trading strategies that are different than typical mutual fund buy and hold strategies. Sometimes these strategies have resulted in superior returns, sometimes they have not.

People's hard earned money should be permitted to flow in whichever direction the advisor and the client deem is appropriate, given the level of risk a client is willing to accept, provided that it falls within the parameters of his/her investment objectives.

There should be a regulatory process in place that puts regulations on the Hedge Fund Industry, but works towards allowing all investors to participate in them, without regard to NET WORTH


David L. Spurr
Wilmington MA