Subject: File No. S7-14-11
From: John T. Battin

November 29, 2013

Why bother with the Dodd-Frank law at all if there is no risk retention by lenders? That's the central issue. If an institution can't bear the risk of holding even a small portion of the loans it underwrites, an investor buying such a mortgage is going to require quite a high yield as compensation, raising consumer costs. If you personally were offered such an investment,would you take it, based on the history of these deals? Not holding lenders accountable for their underwriting practices is poor regulation of an industry that has proven again and again and again that it cannot be trusted.