Subject: File No. S7-25-06
From: Michael D. Rubin
Affiliation: Architect - various affiliations

February 4, 2007

The proposed rule changes are discriminatory and anti-Constitutional. We have long since done away with property qualifications for voting, and with other forms of discrimination throughout our society.

Quite apart from fairness, other investment vehicles are not without risk, or disappointing performance records, especially recently i.e. conventional mutual funds, debt instruments, household equity, and the deteriorating situation of the Social Security system.

Transparency and a modicum of intelligence will protect small and large investors, as always, whereas regulations always lag reality, and invite clever fraud. Fraud should be prosecuted and punished, no matter that it be perpetrated by hedge fund personnel, stockbrokers, real estate salesmen, or anyone else.


Michael David Rubin