Subject: File No. S7-26-07
From: Jack R. Sauther, CPA
Affiliation: CPA, Investment Advisor Representative, Realtor

November 29, 2007

In regards to the NAR's proposal to allow qualified Realtors to sell tenant-in-common real estate investments without being propertly trained or licensed as securities reps, I find this to be a completely unreasonable proposal.

I am a CPA, investment advisor representative and licensed Realtor who believes certain TIC investments provide a suitable investment opportunity for SOME investors. I know and have worked with many Realtors, and I can think of very few, if any, that would take the steps to learn of a client's overall financial situation, goals, risk tolerance, diversification and investment suitability prior to recommending a particular investment. As a CPA and securities rep, I am trained to perform this analysis which is the most critical part of recommending an investment to a client.

Having operated in the real estate sales arena, I can vouch for the fact that it is a very unregulated and unsupervised industry as opposed to the tightly regulated securities industry. It is my opinion that, due to the lack of regulation and supervision in the real estate industry, investors would be placed at a higher risk of investing in a TIC which may be completely unsuitable for them in their presesnt financial situation if a securities representative was not involved in the investment decision making process.

This being said, I DO believe a competent and experienced commercial realtor can provide value to a TIC investment decision. However, I believe the best framework to work within is to have a realtor who does not choose to becoming a licensed securities rep refer the TIC customer to a registered securities rep who can then do a suitability analysis and talk to the client about risk tolerance, investment goals, diversification, etc. The registered rep's broker dealer should then be allowed to compensate the referring realtor a referral fee for the referral. In a perfect world, the registered rep and realtor would work together to advise the client on a suitable TIC property investment.

Thank you for your time.

Jack Sauther, CPA, Investment Advisor Rep, Realtor
1031 Exchange Solutions
Montana Wealth Management
2020 Charlotte St.
Bozeman, MT 59718
406-586-0356