Subject: File No. S7-07-12
From: HUNTER DURHAM
Affiliation: ATTORNEY

December 21, 2012

THE PROVISIONS WHICH ALLOW FOR THE GENERAL SOLICITATION AND SOME ADVERTISING SHOULD BE ADOPTED ESPECIALLY WHEN THE FINAL PURCHASER MUST BE AN ACCREDITED INVESTORS. THESE ACCREDITED INVESTORS ARE OBVIOUSLY WORTH SUFFICIENT AMOUNTS AS TO DEFEND FOR THEMSELVES. SINCE THEY HAVE MADE MONEY AND ASSETS FOR THEMSELVES THAT ARE OF THE NATURE OF AN ACCREDITED INVESTOR, THEY DO NOT NEED THE PROTECTION FROM OVERREACHING, BORROWING FUNDS OR NOT BEING RESTRICTED LIKE NON-ACCREDITED INVESTORS.
I AM DISAPPOINTED THAT RULES AND REGS WERE NOT MADE BY THE APRIL 1, 2012 DATE AS THE LAW PROVIDED.
I FULLY SUPPORT THE JOBS ACT AS IT APPLIES TO 506 REGULATION D TYPE OFFERINGS.