From: Mitchell Disney
Sent: January 28, 2007
Subject: File No. S7-25-06

I would like to go on record as opposing any change that would raise the net-worth requirement for investments in hedge funds. My current net worth would make me eligible to invest in hedge funds, but I would be excluded under the new rules. The exclusion based on net worth, alone, while offering an attractive "bright line" of separation based on wealth, fails to address the commission's real concern, which is protecting investors. Investor sophistication is not determined by wealth.

Instead of the proposed rule, I favor the proposal by Commissioner Campos, which would involve easing marketing restrictions for hedge fund advisers that register with the SEC and submit themselves to a degree of regulatory oversight. I believe the most appropriate way forward is an outcome that increases disclosure and counsel to investors, not one that blindly excludes them based on the amount of their assets.

Mitchell Disney