Subject: File No. S7-25-06
From: Susan H. Thomas-Dibden

January 29, 2007

Raising the bar for investor eligibility only further disadvantages U.S. citizens by restricting their access to investment products. The wealthy, by virtue of the size of their assets, have a broader offering of investment products available. U.S. citizens are restricted from investing in hedge funds because of requirements to invest substantial amounts in single funds due to governmental regulations on U.S. citizens as investors. Reducing the minimum investment required in these vehicles actually minimizes the overall risk weighting in an investor's portfolio, allowing an individual to allocate a smaller percentage of investment assets to this asset class. With the volatility of the stock market in recent years (2000-2006), stocks are not necessarily a safer asset class. We are now on record highs for most markets now, but individual investors lost significant amounts in 2000-2003. Increased eligibility for a broader choice of investment products will allow individual investors a chance to diversify their overall portfolio risk weightings.