Subject: File No. S7-26-07
From: Burke Dambly, CPA
Affiliation: Private Asset Group, Inc.

November 15, 2007

If brokers/realtors want to share in commissions, why can't they simply get a securities license and abide by securities laws and regulations? The Series 22 exam is not any more difficult than state real estate exams.

The ruling will only succeed in engouraging realtors to violate every advertising and soliciting rule ever put in place by the SEC and FINRA.

What happens to a broker/realtor when a TIC offering underperforms or fails and there is litigation? Are they liable? Are they bound by the arbitration rules or do they get sued through the court system?

Broker/realtors already work in an unregulated enrironment that in no way protects investors. They will only bring their unregulated business practices to the securities world.