Subject: File No. S7-04-11
From: Robert A Newman
Affiliation: Financial Advsor

February 9, 2011

In my opinion, it would be better to design a risk assessment formula to be used in determining a persons eligibility for these types of investments. Many individuals retiring are looking for yield. Although the returns are not guaranteed, there are many limited partnerships that have a long history of paying consistent returns in excess of CD's, mutual funds, etc. and would make suitable investments for individuals with portfolio's in the 750,000 and up range. All this rule will do is limit an individual's choices.