Subject: File No. S7-26-07
From: james swanson

November 29, 2007

I am currently a commercial Real Estate broker. Previously, I had been involved in companies on Wall Street and dealt with investments and investment analysis for about 10 years. In the case of TIC investments, commercial brokers are better trained and qualified to ascertain the relative quality of TIC investments than a general securities dealer.

The real commercial estate community understands the underlying value of a real estate investment based on extensive experience that is continuously tested and refined in the marketplace. A commercial agent who gives poor advice or selects investment options based on faulty analysis is pruned from the market by a lack of clients who trust in him/her. Whereas, a securities dealer license is granted to a dealer with almost no knowledge of specific markets and trends that impact the long-term value of real estate investments. While a securities dealer is also subject to market pruning and testing, they deal in dozens of other types of investment options and by virtue of the securities dealer designation, they have no real training in evaluation of real estate opportunities. Furthermore, when a commercial client is evaluating various opportunities, the direct purchase and management of a commercial asset should be weighed with the various TIC opportunities also available at that time. By requiring these clients to get their advice from multiple, unconnected sources, the investor will find it more difficult to compare the relative appropriateness of the choices before him/her.

The community of TIC investors is better served, therefore, by complementing their team of advisors to include qualified Commercial Real Estate professionals to help them make good decisions when selecting an investment.