Subject: S7-26-07

November 22, 2007

Dear Ms. Nancy M. Morris:

Dear Ms. Morris:

I would like to weigh in on the commission issue surrounding TIC interests. As a commercial real estate broker with a CCIM designation, I find the idea of excluding real estate brokers from receiving commission selfish and harmful to the public. Many folks who may purchase TIC interests are those who have spent a lifetime creating enough savings to afford such interests and have considerable equity in other real estate investments. They are not interested in putting their equity behind the debt that most TICs require! These folks are entitled to expert and unbiased counsel regarding real estate investments. Stock brokers are not equipped to offer such counsel and cannot offer the public such expertise. By taking the Real Estate broker out of the commission structure, the public loses the insight of the real estate professional to help them make the right decision for their circumstances.

I urge you to allow the real estate community to be entitled to compensation when a client’s goals are best served by a TIC investment.


Daniel C. Zabel