Subject: File No. S7-26-07
From: Jack W Ellison
Affiliation: Registered Representative

November 14, 2007

Regarding the subject above allowing Commercial Realtors, with certain qualifications, to participate in securitized 1031 Exchange programs involving TICs, I am both a Realtor and Registered Representative. I believe the SEC should allow the Commercial Realtor to be allowed to accept a referral fee from a Registered Representative in a 1031 TIC transaction, but the RR should be the involved party with the client. Allowing the Commercial Realtor to participate 100%, if that indeed is the interpretation of the ruling, is the same as allowing that same person to participate in a transaction that currently requires a Series 7 license, such as the sale of stocks or mutual funds. Those of us who effect 1031 TIC transactions would welcome referrals from Commercial Realtors, and gladly share through the referral fee process, in any renumeration earned. However, the client should be referred to the RR by the CR and the RR should effect the transaction.