November 19, 2007

Dear Ms. Nancy M. Morris:

I am writing in support of File No. S7-26-07 which, if adopted, would allow licensed real estate brokers to be compensated for their real estate expertise in securitized Tenant-in-Common (TIC) transactions.

I agree that the Commercial Real Estate Professional should have "substantial experience in commercial real estate". Here are some ideas for defining 'substantial experience in commercial real estate':

*Having five (5) or more years full-time experience in a real estate brokerage practice that is 85% or greater focused on commercial real estate; or (not 'and')

*Having an advanced degree such as a Juris Doctor degree, Masters in Business Administration or Masters of Accounting from accredited universities; or (not 'and')

*Having a CCIM (Certified Commercial Investment Member) designation.

If you have questions about my recommendations, please email me or call me at 303-665-6000.

Thank you,

Mark Casey
President / Broker
Casey Partners, Ltd.
Real Estate Advisory Services