Subject: File No. S7-18-09
From: David R Pohndorf
Affiliation: Managing Director, Source Capital Group, Inc., Mbr., FINRA

August 4, 2009

I have worked for twenty years as a registered investment banker, first in the traditional private placement field, marketing debt and/or equity securities to institutional investors, and for the majority of years, specializing in marketing private equity partnership interests to institutional investors, i.e., qualified investors under SEC rules.

I have marketed private equity partnership interests to several public retirement systems, including New York State Common, New York State Teachers, CalPERS and CalStrs.
My last activity with New York State Common Retirement System was in 1991. I would note that at that time, Ned Regan was the sole trustee. I was a principal with the Whitman Heffernan Rhein Workout Fund, which received a
$ 35 million commitment from NYS Common. A couple of years later, a new sole trustee was in place and our fund began to receive invitations to fundraising events for the new trustee with suggested donation amounts. I thought then, as I do today, that such solicitations were illegal, or at least not in the spirit of the law.

At no time over twenty years have I ever made donations to politicians related to any public fund.

(Attached File #1: s71809-3.pdf)