Subject: File No. S7-25-06
From: JEFFREY R NEUFELD

February 2, 2007

Ah yes, the great SEC is out to get the big bad hedge funds again, but this time they're going through the back door--the little investor. I think any arbitrary net worth minimum to investing in hedge funds is illogical whether it's 1 or 2.5 million. The land of opportunity has become the land of "what color is your ticket?"

Consider Bob Bucks who just retired yesterday from his company. He was fortunate to have saved smartly and religously and is entering retirement with $999,998. But wait, according to the SEC he is not intelligent enough to invest in hedge funds. Walking home disappointed from his broker's office after being told of the $1,000,000 minimum, he discovers a five dollar bill laying in the gutter. Great Day He now has $1,000,003 He quickly returns to his broker and jubilently invests in Big Time Returns, LLC. So what happened: was there a voice and blinding light from heaven? Did an apple fall on his head? Did the Monopoly guy blow some fairy dust on our friend? Was an honory MBA in Finance granted to him? How was our hero suddenly deemed worthy to invest in his favorite hedge fund? You guessed it, the "fiver" he found put him over the SEC's magical line.

Apparently, like Harry Potter learning a new spell, the SEC has found that 2.5 mil is even more magical than just 1 mil. Those single-millionaires are such shmucks after all. I just feel sorry for those poor souls who in the future will get a $2,499,999 inheritance from Aunt Sally but will find themselves booted out onto the garbage heap at their neighborhood hedge fund shop.

In other words, dear SEC, this is a BAD IDEA, not to mention completely un-American.