From: David Wilhelm
Sent: January 26, 2007
Subject: File No. S7-25-06

To Whom It May Concern:

I believe the concept that only "accredited investors" be allowed to participate in that group of investments including hedge funds is preposterous. I invest in a number of such funds and know and have dealt with a ton of accredited investors particularly in my past. The presumption of the current law is that if you have money or certain net worth you are financially wise, sophisticated and able therefore to participate in these funds. I would say that nothing could be farther from the truth with a large number of people that have inherited their wealth from family. death or divorce. It seems to me the obvious thing to do is to establish some means of measuring an investors knowledge and assuming they possess that knowledge allow them to participate in that group of investments irrespective of their net worth. Reserving these investments for the rich is discriminatory not to mention polarizing to our society. There are many up and coming professionals that are conservative and prudent but without a large net worth but that have a far greater interest, knowledge and ability to evaluate these investments than a good number of current wealthy accredited investors.

I don't profess to have the answer as to how best measure those that should or should not be able to participate. I am sure that there are many very qualified people that would both have the knowledge and willingness to put forward some good ideas to solve this problem. I thank you for the opportunity to comment.

David Wilhelm

Wilhelm Company
David C Wilhelm, Jr.
333 Logan Street, Suite 100
Denver, CO 80203
Tel: 303-282-8850