Subject: File No. S7-25-06
From: Stephen R Adams, Ph.D.

January 29, 2007

I am disappointed in the proposed increases in the net worth of a person to qualify as an accredited natural person.

The fundamental premise of the current rules is that because I am not yet rich, I must be too stupid to understand these investments and too stupid to seek professional advice. Therefore I must be protected against myself by a rule that serves to give those with the advantage of wealth the additional advantage of broader opportunities for increasing their wealth. At its core this rule is no different from, say, a rule prohibiting a person of color to own property, or a rule prohibiting a person not owning property to vote. It is that offensive.

My financial life is already complex. I have to research and make decisions about many classes of investment. My employment package includes stock options and a share purchase plan. My 401k choices are always changing. I have a mortgage on a home. I can short stocks, invest in currencies and commodities in my brokerage accounts. All these carry risks which could be my financial ruin if I choose foolishly. With adequate disclosure, investing in hedge funds is no different.

My belief is that the SEC should strive to remove this financial apartheid.

I would support a proposal like that for a regulated Hedge Fund Investment Company as put forward by Roel Campos.