Subject: File No. S7-25-06
From: Josh Allen
Affiliation: Commodity investor, former fund mangaer, and real estate sales manager

January 27, 2007

I am adamantly opposed to raising the net worth standards from $1,000,000 to $2.5 million. I think the notion that a net worth suddenly qualifies a person as "sophisticated" is rooted in social bias against a growing and educated population. How can you suggest that someone has the capacity to comprehend understand a one directional investment vehicle of stocks, bonds, commodities, real estate, oil, and energy and suddenly not be able to understand or study the risks associated with hedge funds. I think it is absolutely ludricrous and I agree wholeheartedly with the words of John Mauldin who authors a weekly email sent to ove 1,000,000 investors of all net worth status who stated the following:

If you were to tell investors that they would be discriminated against because of their gender or race or sexual preference, there would be an outcry. To put it simply: it is a matter of Choice. It is a matter of Equal Access. It is a matter of Equal Opportunity. Congress should change the rules and allow all investors to be truly equal, at least as to opportunity.

I believe it is time to change a system where 95% (and maybe soon to be almost 99%) of Americans are relegated to second-class status based solely on their income and wealth and not on their abilities. It is simply wrong to deny a person equal opportunity and access to what many feel are the best managers in the world, based upon old rules designed for a different time and different purpose. I hope that someday Congress will see to it that small investors are invited to sit at the table as equals with the rich.

Thank you for removing this rule and considering with appropriate notice and oversight opening the alternative investment vehicle to Americans of all race, age, and financial status.

Thank you for your consideration of my honest comments.