Subject: File No. S7-25-06
From: David M Levin
Affiliation: CIO Computime Institutional Services Inc.

January 29, 2007

The mandate of the SEC is to protect the investing public on the basis of some reasonable and/or equitable rules.

The most logical basis would be the historical track record of available investment vehicles:

The vehicles with higher volatilities, and
lower investment returns need the most stringent
oversight and protection by the SEC.

The vehicles with the most stable returns would need
the least oversight and protection by the SEC.

It can be demonstrated that Hedge Funds have shown annual average returns and non-volatility no worse than Mutual Funds, or stock indices in general.

Accordingly, there should be no "sophisticated investor" financial requirements for investing in Hedge Funds.