Subject: File No. S7-26-07
From: Rick Willoughby
Affiliation: Member NAR, Registered Principal

November 15, 2007

I have been a Realtor since 1972 and a Registered Representative since 1999 and firmly believe an exemption would cause great and significant harm both to the public and the TIC industry as a whole.

Having been involved in both industries I can attest to the fact that there are distinct cultural differences between the real estate licensee and the registered representative.

The idea that someone from the real estate industry would ever consider the best interests of a client over their own is at best far fetched. The culture of the real estate business is they look for a "Ready, willing and able buyer" that is what they do. They DO NOT look for a suitable investment for a client. To think that a few unenforcable rules would stop a Realtor from puffing a property or general solicitation is absurd.

I hope for the good of the public the SEC will not bow down to the huge NAR and stand firm.

I belive the exemption prostitutes the SEC and is simply a sell out to the much larger real estate industry. TIC's are clearly securities otherwise there would be no need for an exemption, securites are sold by registered representatives not real estate agents.