Subject: File No. S7-18-09
From: Scott Allen
Affiliation: President, Tava Development Co.

September 30, 2009

As a real estate developer and homebuilder one of the largest constraits to our business is the availablity of capital. Our industry relies on large public and private funds to provide the capital that builds American. Most real estate development and construction businesses are small regional operations that do not have direct access to public pension funds. With out the investment bankers or placement agents that have the connections to these capital sources housing in this county will become more difficult to obtain and more expensive for our citizens.

I urge you to reconsider the provision in this important regulation what would prevent the use of investment bankers or placment agents.