November 19, 2007

Good Morning,

I do not agree that an exemption should be granted in compensating real estate agents for engaging in securities transactions. I have been a registered principal for over ten years and worked as stockbroker for a total of 13 years. After leaving the profession I have become a licensed real estate broker and in general, I believe the education, experience and regulatory function in the real estate market is flimsy at best.

In the practice of real estate obtaining a “required number” of transactions does not prove competence or in-depth knowledge of anything. I am shocked at the price-projecting and other practices I witness among the agents that serve the real estate investor market…this TIC product is too sophisticated for most agents and their clients to grasp properly and for that reason proper disclosure will be lacking.

This product is pitched to investors as “safer” than other forms of real estate investing and that initial premise is the reason for its popularity. It masks the speculative aspects of the transaction and inflates the potential return. There are plenty of intangible products for investors to seek out who do not have the “pockets” to invest in real estate. And as in other categories of business such as banks becoming commercial real estate holders, the public is better served by keeping these two circles of influence separate. As to the validity of the training offered to commercial real estate practitioners one could says it falls under the same philosophy as the Uniform Securities Act, that to say you are an registered investment advisor (on your business cards, etc.,) is to infer that you have knowledge and experience that you may not actually have acquired.

I expect that the public will have the same misconception about the newly-graduated commercial real estate license holder.

Thank you for your time and attention to my opinion.

Regards,

Jay Music, Broker/ REALTOR®
Central Carolina Realty
...where You are Central