Subject: File No. S7-26-07
From: Ronald F Helle, CPACFPPFS

November 14, 2007

I am opposed to any attempt to allow realtors who are not licensed to sell securities to be allowed to sell or receive a commission for the sale of a TIC. One only has to look at the subprime leading problem to see what happens when an industries' only concern is to" make the deal". In today's investment environment too many potential clients simply are not adequately educated on the consequences of the transactions they are about to enter into and the real estate profession as a whole has too many individual realtors who themselves are not properly trained in tax, cash flow and securities regulations. If a realtor is really interested in the TIC business they can simply go thru the same process as all the other individuals who studied and passed the series 7 exam. It is these people who pay for the the compliance and self regulation of the profession. To allow non NASD licensed individuals to market TIC real estate would be deterimental to both professions.