Subject: File No. S7-25-06
From: Michael Pace, CFP
Affiliation: Fee-only Registered Investment Advisor

March 8, 2007

Dear SEC:

It is my understanding that the SEC has a variety of concerns about hedge funds and, as a result, has drafted language to raise the threshold for qualifying as an Accredited Investor. However, it appears that the scope would go far beyond only hedge fund investors, and would cover many other investments. If this is the case, the proposed language would have a horribly counter-productive effect on investors who are currently qualified under the current Accredited Investor definitions.

Under the current rules, my clients are able to invest in alternative investments offered across a variety of investment sectors by very reputable investment companies. These trust-worthy companies are conservative in nature, and their investments help tremendously to diversify my clients portfolios away from the often volatile domestic and international stock markets.

Without the opportunity to access non-hedge fund alternative investments, tomorrows investment portfolios would not be able to balance equity ownership, safety and stability like they are today.

If the proposed language goes into effect, future portfolios could well find themselves in a seriously under-diversified investment world. No investor deserves to have more risk and periods of negative stock market returns forced onto them.

I am a state-registered, fee-only advisor, and I act as a fiduciary for my clients. None of my clients invest in hedge funds. Please find a way to address your concern about investing in hedge funds without putting my clients futures at greater risk.

Michael Pace, CFP
NAPFA-Registered Financial Advisor
7812 Stone Avenue North
Seattle, WA 98103
206.522.7812
michael@michaelpace.net