November 13, 2007
As a Financial Professional serving the needs of the public at large and in an attempt to identify what types of investments are appropriate, I feel it is not in the best interest of those we serve to allow those who are not trained to identify the risks associated with TIC transactions to represent such to the buying public. The proposal by NAR, while it attempts to place training and education in the Real Estate business as a criteria for qualifications, it does not address the responsibilities which the SEC places on those in the financial services business. These are 1) to know your customer, 2) to assess their risk tolerance, 3) address their long-term financial objectives, 4)to assess their liquidity concerns that such investments are non-liquid assets 5) to help clients and customers with the overall balance of their portfolios. In the capacity of a Real Estate Professional, the goal and objective is more directed as one of transactional in nature and therefore the balance of assets would not be a consideration in that transaction. This is what the Professional Financial Advisor does in their relationships with clients. Bottom line, Real Estate Professionals should stay within the area of their expertise and leave the balance of financial assessments and allocations to the Financial Advisors.