Subject: File No. S7-26-07
From: David E Massa
Affiliation: CCIM, Series 22 and 63

November 14, 2007

The experience requirement should be simply having a real estate license. The reason that the TIC purchaser is being referred to a registered representative is to assure the purchaser that he is working with someone adequately trained and licensed for the sale of the relevant asset type, the TIC. The referrers experience is therefore irrelevant. The referral should be encouraged because it is in this way that the public is better served. Also, any licensee with so much commercial experience will likely secure the interests of his client into a non-TIC asset for the simple reason that the commission of such an asset is very much higher.