Subject: File No. S7-18-09
From: Alan Fields

October 6, 2009

Registered placement agents play an important role in introducing Investment Advisers to institutional investors as they are capable of promoting high quality funds that may otherwise go unnoticed. We believe any responsible registered placement agent of good quality would perform a significant amount of due diligence before recommending these fund managers. Their work is quite helpful in supplementing our internal research efforts.
We also believe that there is a higher potential for returns with the expertise of placement agents as they bring about investment opportunities in emerging fund managers and funds located outside of the U.S.
In summary, registered placement agents are valuable intermediaries between investors and Investment Advisers with the extensive research, analysis, and knowledge of a wide range of investment opportunities.