Subject: File No. S7-34-11
From: William Turner, Esquire
Affiliation: Attorney

September 1, 2011

As a bankruptcy attorney, I have some experience in the harms caused by how the pooling of mortgages was handled, which led to the housing collapse. However, I do not see REITS as causing this problem, particularly those dealing solely with government backed pools like Annaly and AGNC. I am invested in these types of companies, and I do not need protection from the SEC.
I think this proposed rule change would cause more harm than good. These REIT companies serve an invaluable function to our economy by helping to facilitate the availability of mortgages. Again, too much of a good thing can be a serious problem, but the REITS did not cause the crisis.