November 19, 2007

Release Number 34-56779 was of great interest to me because a majority of the business of my small, niche broker-dealer is the offering and sale of TIC/1031 real estate securities transactions. It is difficult to predict whether the proposed exemption will adequately protect the public interest and investors which is stated to be the primary objective of the SEC. Although the proposed exemption has a number of requirements, restrictions, limitations and disclosures, the real estate industry is relatively unregulated, certainly, when compared to the broker-dealer industry. Therefore, it is my belief that additional requirements should be considered by the SEC as follows:

Thank you for your kind consideration.

Respectfully,

Richard A. Leach
INVESTMENT SECURITY CORPORATION