Subject: File No. S7-04-11
From: Peter Papagianakis
Affiliation: Managing Member of law firm

January 26, 2011

Generally, I agree with the SEC proposed changes to the definition of "Accredited Investor."

However, for the sake of consistency, I suggest that the SEC's use of the word "property" in the proposed rule should be replaced with the words "primary residence."

The Dodd-Frank statute uses the words "primary residence," not the word "property" (which, as attorneys know, may mean personal property or, as intended in this case, real (estate) property).