Subject: File No. S7-26-07
From: Corbin E Turpin
Affiliation: I am S-24, S-7, 65 and 63 PLUS a Commercial Realtor/NAR Member/CCIM Member

December 6, 2007

I don't believe that most commercial realtors have the experience and/or the experience/education to work with TIC transactions.

I have been a commercial Realtor since 2002 and a Broker as well as CCIM Member...I feel that I've had much more experience in commercial properties than most commercial Realtors including foreign transactions, working on deals over one billion dollars and working in all facets from bare land to amusement parks but, if I had not had the experience as a Series 7 or Series 65, I don't feel that TIC transactions would be within my scope of practice.

Sure, if I had not ever been licensed as a Series 7 or 65 advisor, I'd probably still think I could handle those transactions as a Commercial Realtor...but, I feel it would have been a dis-service for my clients because of my lack of realization of the fiduciary responsibility and ability to compare investment alternatives.

Please contact me if you'd like more input (913) 908-4848.