This document is available in two formats: this web page (for browsing content) and PDF (comparable to original document formatting). To view the PDF you will need Acrobat Reader, which may be downloaded from the Adobe site. For an official signed copy, please contact the Antitrust Documents Group.

Comment No.: REW-0017
Received:

October 18, 2005

Organization: Thomas & Thomas Properties, Inc.
Commenter: Thomas, Robert
State: VA
Attachments: None


Comments:

From: rkthomas2@mris.com [mailto:rkthomas2@mris.com]
Sent: Tuesday, October 18, 2005 7:32 PM
To: ATR-Real Estate Workshop
Subject: A certain lack of competition

Thomas & Thomas Properties, Inc.
P.O. Box 8026, Fredericksburg, VA 22404
Tel. (540) 368 2452 Fax. (703) 783-1329
Email: rkthomas2@mris.com

To Whom It May Concern: 10/18/2005

From: Robert Thomas

Subj: Competition in the Real Estate Workshop Project V050015

There is a lack of competition in a certain area of real estate, but not because of the real estate industry. I am a licensed broker in Maryland, Virginia, District of Columbia, Florida and New Mexico. I wish to point out an area in the sale of real estate where there is very little competition, i.e. the sale of tenants-in-common (TIC) fractional parts of large buildings to small investors. A TIC is a sale of actual real estate, recognized as such by the IRS, because it qualities for the 1031 exchange of investor funds from one property to another. However, this sale of real estate can only be handled by securities licensees, not by real estate agents. Securities sellers are regulated by the SEC which severely limits their numbers. Entry into real estate is state regulated and relatively easy, thereby making for lots of agents and heightened competition. But there are few sellers of securities and always will be, hence little competition. This does not serve the public interest.