Subject: File No. S7-25-06
From: Gary R Greenbaum, CFA, CAIA
Affiliation: Greenbaum and Orecchio, Inc.

February 1, 2007

Please consider adding another exemption to your proposed category of "accredited natural person". I suggest adding an exemption (from the proposed $2.5 million asset requirement) for investors who:

1. are already accredited (Rule 501(a) of Reg D), and
2. have completed a comprehensive personal financial plan, and,
3. have retained a registered investment advisor that always maintains a fiduciary relationship with the investor, and
4. have retained a registered investment advisor that maintains robust professional credentials (ie CFA, CIMA, CFP, CIC, AIF, CIMA), and
5. have retained a registered investment advisor that uses technology sophisticated enough to forecast a reduction of overall risk levels in client portfolios when the portfolios include some alternative investments.