Subject: File No. S7-26-07

December 4, 2007

Comment on proposed rule:

Adopting this rule will not create an incentive for commercial real estate brokers to sell TICs, over other real estate. For an experienced commercial broker, a TIC is his last choice for two reasons:

Having sold commercial real estate for 20 years, including a few TICs through a registered rep, I believe TICs are appropriate only for 1031 buyers who want to be ďhands offĒ and donít have enough cash from their 1031 to buy 100% of a nice property. "Not enough cash" means less than about $500,000. The TIC industry recognizes this since most minimums are in the $200,000 to $500,000 range.

For these reasons donít expect there to be a big rush of commercial real estate brokers selling TICs if this rule is adopted. One impact will be some brokers who canít find suitable properties for their small investors may direct them to a TIC, for which they rightly deserve to be compensated.

The primary impact will be to allow investors to receive advice from real estate professionals on a proposed real estate investment. Now why would the TIC industry resist that concept??

Jack Hanlon, Dunton Commercial Real Estate