Subject: File No. S7-25-06
From: Vivek Viswanathan

February 24, 2007

Inflation may have well pushed many into the accredited investor category that you did not originally intend to fall into that category.

However, there is an important point being missed about the very idea of a minimum asset threshold to determine how sophisticated an investor is. There must be a way to get around that asset minimum that involves demonstrating knowledge--perhaps through a simple test of knowledge.

In low risk premium environments, investors cannot be content to earn beta, whether that is a rich investor or one of average wealth. To cut that option off from the investor of average wealth is forever consigning him to a life of market returns.

Give that investor a way to prove his or her financial sophistication that does not involve net worth, and you will both encourage financial literacy and give investors the crucial ability to more efficiently allocate capital.