Subject: File No. S7-26-07
From: Ron Beech
Affiliation: Commercial Realtor

December 6, 2007

After reading the responses about this matter, it is clear that broker dealers are against this issue. I am certain that the majority of them are against the issues because it will reduce their income not because of their concern about the public buying the wrong investment.

If they are concerned about protecting the public then they should not sell a TIC until they obtain some type of special certification. This is important because their current training does not prepare them to explain or analyze a TIC for a client. Unless a broker dealer understands the terminology of the underlying investment, (Real Estate) how can they help their client?

Right now, I am looking at a Due Diligence manual for a TIC investment. There is terminology in the projections that a broker dealer is not qualified to understand or explain to someone else. An example of some of the terms are:

Rent Abatements
Base Rental Step Revenue
Full Service

Additionally, a broker dealer has no sense of context when they review a TIC with a client. For example, if the projections state that the management fee for the property will be 7%. How would they know that on average, the industry charges 4 5 percent for property management?

As a commercial broker, I dont understand security laws. However, I do want to sell TICs because I think they are a great investment for real estate investors that do not want to actively manage property. Also, I do want to make money when my client buys a TIC.

I think the SEC should require every broker dealer and Realtor to obtain special certification to be involved in a TIC transaction. Commercial Realtors need knowledge of security laws and broker dealers need a lot more knowledge about commercial real estate.

I hope the SEC will develop a realistic solution that truly protects the public instead of listening to the lobbyist that represent both the real estate brokerage and securities industries.