Subject: File No. 265-27
From: Timothy J Kruse
Affiliation: Business Broker

September 14, 2011

Please address the issue of issuing some sort of broker dealer lite license for business brokers and other intermediaries who sell small businesses and assist them in raising capital. Presently business brokers have one of three options:
Be licensed Investment Bankers
Be licensed Real Estate Brokers
Have no license

None of the current options are acceptable. The investment banking license is designed for those working with publically traded companies, the real estate license is designed for those selling real estate and obviously having no regulation is less desirable than a formalized, but appropriate, licensing process.

I believe your committee has such recommendations from the ABA, the IBBA and other associations. Please consider them.

Tim Kruse
Kruse Acquisitions, LLC