Subject: File No. S7-25-06
From: Robert Byrns, CFP,EA
Affiliation: NAEA FPA

January 28, 2007

Dollar amounts do no define an an individuals ability to grasp the wisdom or apporopriateness of hedge funds. A willingness to be educated is the real requirement.
To limit individuals based on an arbitrary threshold is not appropriate. I think the burden should be on the IAR, similar to how Great Brittain approaches the matter.
It is our job to evaluate the client's risk tolerance and to determine if they are truly a sophisticated investor. I have over 500 clients and 200 million under advismentment and I have very few individuals regardless of income that have the financial acumen and ability to absorb these potential losses, so I have only a handful where this is appropriate.
It is more a matter of circumstance that the total of ones
If the amount is to be adjusted, anything in excess of 2 million would be total overkill, inflation adjusted since 1982.