Subject: File No. S7-34-11
From: Jeffrey Sargeant

September 22, 2011

The proposal to modify existing REIT regulations and statutes is counter-productive to long and well-established policy and guidance and should therefore not be implemented. This is especially true when considered in light of the fact that the SEC has already accomplished its goal of alerting the industry that the SEC is closely monitoring the sector and watching for any malfeasance or manipulation that can sometimes occur in a hot market sector.

The REIT sector thrives or languishes at the whim of prevailing interest rates. With this crucial factor set and governed by the Federal Reserve the REIT sector is already, as it were, regulated and constrained by external and significant managers. While it is indeed true that REITs are hot right now due to the attractive spread in interest-rates and rate-policy as outlined by the Federal Reserve, it is expected that rates will indeed rise in the future which will have the requisite effect of cooling off the industry in its typically cyclical environment. Intervention by the SEC to cool-off this sector is neither desired nor needed given these constraints.

Indeed, the SEC has already accomplished significant goals by simply floating this proposal, leaving the end-result relatively moot. Since the SEC announcement the sector has drifted downward in essence, it has cooled off. And with the announcement the SEC has warned the sector and affirmed with the public that it is closely monitoring the sector for any abuses that may have a negative impact on investors or the public at large. With these goals achieved further regulation or change to this sector is superfluous and will have long-term detrimental effects on the investing public, something that is most certainly not the goal of the SEC.

This sector is one of the few bright spots in a seemingly dismal investment arena. While the SEC is doing its job of monitoring and facilitating sector services and shielding investors from predatory practices please give careful consideration to the negative impact this proposal will have on not just the REITs themselves, but the investing public as well.