Subject: File No. S7-17-11
From: Troy M Clark

June 23, 2011

I agree with most of the other comments, especially with the ones that say to not exclude the value of one's home in the net worth calculation as this is clearly unfair to home owners versus renters and is not required by the Dodd-Frank bill so please don't do it. Also totally agree with that comments that say if you increase the net worth amount it should be done more slowly over time rather than a big jump all at one time to $2.0M.

I also propose that the SEC take this opportunity created by the Dodd-Frank act to also introduce a new exception to the $1.5M net worth rule.

I think using net worth as the only measure of the sophistication of an investor is flawed. Why?

Many financially sophisticated investors chose to give away much of their net worth to charity. This does not make them less qualified to invest but rather makes them more generous.

Likewise many financially sophisticated investors chose public service careers that pay far less than private sector jobs because they want to serve their country and community. Some highly educated people (Master and PhD degrees)choose to become public servants instead of becoming highly paid doctors, lawyers, or bankers. This doesn't make them less financially literate rather they are just making a different life style choice. For example someone with a master in mathematics becomes a high school teacher instead of getting a much higher paying job on Wall Street can be just as financially sophisticated and literate as a wall street broker. Moreover this public servant may have a big pension instead of his own retirement account contributed to having a lower net worth.

My proposal is to make the following exception to the "qualified client status" (Similar to how you have the $200K a year income exception to the "accredited client status").

If someone has a bachelor degree in a finance related major or a master degree or higher in any major from an accredited U.S. University then they should be allowed to invest as an "qualified client" in a hedge fund regardless of their net worth. In this way generous people who give away a big part of their net worth to charity but our highly educated and sophisticated could still have access to hedge funds. Also in this manner public servants serving our communities and country could also have the opportunity to invest in hedge funds as long as they have a higher educational background proving they are a sophisticated and well educated person.

Thanks you for considering my proposal of adding this new exception, based on an investors educational background, to determining an investors "qualified client" status.