Subject: File No. S7-25-06
From: David G Neale, CIMA, CIS
Affiliation: Marketing Director for Alternative Investments Group of Bank of America, South Region

February 5, 2007

Gentlemen: I speak with many wealthy investors that know little, if anything, about this space. Wealth has little to do with skill and understanding of investments in general. I, on the other hand have worked in the industry for over 25 years and have aspired to acquire sufficient wealth to participate and just as I have reached it, you're pulling it away. There are many in my situation with around $2mm in net worth that would benefit significantly by participating in this asset class and you would be unfairly barring us. Unwary investors will always, unfortunately, fall prey to fraud and I applaud your efforts to protect them. This, however, is a simplistic approach that will do nothing to prevent fraud and simply lock the door for far too many.