Subject: File No. S7-25-06
From: Dennis Shak
Affiliation: Wharton MBA

February 2, 2007

The size of one's investible assets has little to do with one's ability to evaluate investment risks and returns.

The proposal to redefine qualified investors to $2.5M unfairly discriminates against all but the most wealthy and reinforces the perception that the "rich keep getting richer" and you "need money to make money".