Subject: File No. S7-30-04
From: Joseph H Omansky
Affiliation: President, Sky Fund LLC, SkyRank System of Hedge Fund Ratings

September 24, 2004

As many hedge funds represent an investment option with unique advantages, often exhibiting lower risk and higher risk-adjusted returns to traditional investments, we support the mandatory registration of hedge funds for the following reasons:

- The SEC alone cannot reduce fraud through the registration of hedge funds, however by utilizing outsourced contracts with industry professionals, the SEC may have a marked impact on reducing fraud.

- Mandatory registration may indirectly open the industry to more investors, specifically retail unaccredited investors who should have equal access to hedge funds.

- A quantitative system used to assess risk, and rate hedge funds, coupled with standard due diligence for qualitative transparency should be requisite and linked
to SEC standards through outsourced professionals bidding on SEC-mandated projects.

- The outsourced companies should own a workable system that quantifies the risk of hedge funds with multiple hedge fund inputs to measure their appropriateness for
various classes of investors.

- So long as the appropriate hedge fund is identified by the said quantitative system that identifies hedge fund risk, minimum investment should be reduced to allow broader access of hedge funds to a broader class of investor, independent of wealth level.

- Pension funds should be required to utilize such a system as a methodology of identifying appropriate hedge funds for the end user. A certain predefined and
standard percentage of pension assets should be required for allocation to low risk, low leveraged, credible hedge funds as identified by such a quantifiable system.

- A certain amount of allocation should be reserved for the unaccredited investor as equal access to all segments of financial markets should be of paramount concern to
the SEC, other regulators, pension administrators, and industry professionals.

Joseph H. Omansky
Sky Fund LLC
Sky Rank System of Hedge Fund Ratings
The Most Comprehensive Hedge Fund Rating System in the Industry
PO Box 63
New Brunswick, NJ 08903