From: Mike Murray
Sent: August 24, 2007
Subject: File No. S7-18-07

Simply put: I do not know where to begin!
Substituting the word "aggregate" for the word "joint" when defining dual ownership could (possibly) alter the legal definition for properties designated JTWROS, which is intended to ease the transition when one of the parties dies. I know (why didn't we think of this before), let's confuse matters even further by "grandfathering" JTWROS accounts already in place - that will fix things!
And my house; let's see: those $100,000 dollars I paid as a downpayment are not worth what they were 4 years ago (due to inflation), but I count upon them heavily to be there when/if I decide to sell the house. And, although I did purchase it as my primary dwelling, I expect (hope) it to keep up with inflation and appreciate over time, so my house serves a dual purpose as dwelling and investment. Historically, houses have proved to be some of the best investments people have made, and quite often are the best investment for some folks.
Similarly, the $150,000 liquid assts owned by my business (which I keep as a safety net for operations) - that $150k is not significant to anybody - why count it as part of net worth?

It would seem that the "two-tier structure" for minimum net worth requirements in order to participate in certain investments mght better be handled at the "prospectus" level. That is, designating that certain investments might require higher standards than others (presumably) as a measure of the risks associated with particular investments. Since, the regulatory agencies review them already, they could simply include that consideration in their reply notes to the sponsors.
With all the insider trading going on in the "pre-market" activity (simply watch the ticker and compare against news releases), the SEC might consider putting a stop to it by permitting trading only when all of us can participate. The gun should go off for everybody at the same time. Why not go after the real crooks!