From: Neil Brown, CFA
Sent: February 15, 2007
Subject: File No. S7-25-06

This proposed rule raising the minimum net worth requirements for investment in hedge funds does not make sense. We should be finding ways to make alternative investments, including hedge funds and private equity, MORE accessible to the broader population, not less accessible.

Not all hedge fund strategies are alike and it certainly is the case that some are substantially more risky than others. Perhaps there should be a little more leniency in the mutual fund regs to allow for a more flexibility in the funds investment mandate to incorporate hedge fund strategy techniques, which would then have all the oversight of the SEC. This would seem to me to be the more plausible, fair and appropriate approach to hedge fund oversight.

Finally, why is it the case that DC investors are forced to be “long” investors? Nothing could be more risky to a retiree than to force him/her to always be long in an asset class.

Neil Brown CFA