Subject: File No. S7-26-07
From: John Borger, CFP

November 15, 2007

The solution is so simple. There is no need to go through complicated rules and regulations changes, or issue exemptions.

Any real estate agent or real estate broker that wants to offer TICs to their clients can simply work within the existing rules and regulations by easily getting his/her Series 22 license and becoming affiliated with a broker/dealer. This will also give them the background and education to better advise their clients.

Keep it simple. No new rules or exemptions are necessary.