Subject: File No. S7-25-06
From: Benjamin W.

February 24, 2007

Here, in my third comment installment, back by popular demand... (well, one out of two ain't bad).

Having read through the comments, I must agree with the overall persuasion of not only NOT raising hedge fund financial entry level, and not only lowering the minimum level, but completely doing away with it as being obsolete.

Please let me recap reasons: Many that are shared by others.

1. I call this, "The Google Era." Simply stated: ANYONE with a computer can access a hedge fund (though, currently not everyone is allowed to purchase shares in the hedge fund, a.k.a., "investment fund" - Harvey Goldschid, former SEC Commissioner).

However, whoever does NOT have a computer is probably not going to be cutting edge enough to identify a hedge fund anyway, so the concern of their being able to invest in one may be done away with by default.

2. Due to The Google Era, today's enlighted computer user is by far more sophisticated using modern Internet and PC tools than investors were in 1940 and prior when the SEC investors acts were written.

Nowadays, by a few well-placed clicks of a mouse, a TEENAGER can become WAY more "sophisticated" than even the sharpest investors pre-Google/pre-Internet/pre-PC ever dreamed of becoming.

Again, making the "accredited investor" scheme 100% obsolete.

Consequently, the burden is placed on the SEC to become updated, NOT by raising financial access levels to hedge funds.

3. Currency trading, and I speak as an advanced currency trader, can now be accessed by ANYONE with as little as $1.00.

That's right, you can trade foreign exchange currencies by the unit (what used to be done only by the "lot," that is, 100,000-units, and prior to that, 1,000,000-units and so on). This is simply because PC technology has advanced, thus lowering the minimal $ access level.

GONE and OBSOLETE are the days when you had to have $25,000,000 in your account to access this highly risky and volatile market, the ForEx.

By comparison? Setting minimum limits on access to mere hedge funds is LAUGHABLE.

No one, not a single person at the SEC, and most likely not a single person who has posted on this SEC comment thread, is "sophisticated" enough to enter a trade in the ForEx market and do so with much probability of success.

Yet, with margin (leverage) up to 400:1 (and higher) EVERYONE can now access and trade foreign currencies, freely.

Really, guys, and this statement is more directed to the SEC, let's not step backwards in time. Let's get updated.

Let the markets, hedge fund managers, and people themselves set naturally-occurring financial access levels to hedge funds, and to markets. Freely.

It IS doing a great disservice to the broad populous by setting minimal entry levels to hedge funds.

I, for one, would NOT qualify as an "accredited investor," yet, I openly challenge anyone who runs a hedge fund to take the other side of any of my trades.

This offer extends to everyone reading these posts, everyone at the SEC and the entire government base of employee staff. In the USA and anywhere in the world.

Simply stated, I develop and analyse currency trading systems. I have more successful currency trading systems than any of the readers here will ever even think of.

I have proprietary currency exchange technologies that are original and that are so advanced, I've done away with drawdown and volatility completely. Applied, they could wipe out the national debt in 3 to 5 years.

Breakthroughs. Advancements. Not due exclusively to me, an average guy, but due mainly to technology, progressive thought, the Google Era, and the Internet. Hard work as well. :-)

What I'm saying is, for the SEC to place financial limits on ME, as NOT being an "accredited natural person," who, in reality, can out-maneuver, out-trade and out-exchange any HF manager, any team of bank "currency strategists," any "quant," or "accredited investors," with my eyes closed... goes off the scale for being a ridiculous measure.

Our Government cannot afford to continue to make up ridiculous, outdated laws and rules.

Please just stick to policing fraud and misrepresentation, and to teaching people things already pointed out on this SEC thread.

Thank you,

advanced currency trader