Subject: File No. S7-25-06
From: Jack Outhier
Affiliation: Investment Advisor

February 24, 2007

Because the intent of the law is to protect "unsophisticated investors" rather than to further extend a class distinction between the "haves" and the "have nots", something beyond personal wealth MUST be used as an indicator.

As an exam for investors is impractical, why not an exam for Investment Advisors and then limit these investments to those investors who hire the accredited advisors? That, in itself, will demonstrate an appropriate level of investor sophistication by virtue of their not "going it alone" but turning to professional advisors. Further, it places the advisor in the position of responsibility/liability in the event something is done inappropriately, as in too high an allocation to one position, too great illiquidity at an advanced age, etc.

For these reasons, I believe changing the "accredited investor" definition to a higher threshold is simply the wrong approach and unnecessarily limits the less wealthy from accumulating sufficient retirement funds.