September 3, 2011
I do not have the background or expertise to comment on the very detailed requests in the SEC's two documents on Asset Backed Investments. Having read the documents it appears most of the intent is to protect the investor and provide greater transparency. As a small investor in several mortgage REITs I have no objection to this, although I have found all information and reports presented by these companies to be clear and comprehensive. I have even found many to go out of their way to educate the small investor.
As stated in your documents, these REITs provide access to the small investor to pools of securities that might otherwise only be available to the large or institutional investor. Any action by the SEC to radically alter this access would be a further blow to the small investor, already disadvantaged by large institutions.
It's an unfortunate side effect of perhaps a necessary review by the SEC, that since the announcement, the market in these companies has been negatively impacted. Inevitably the small investor, whose protection is the goal of the review, is damaged the most. I hope the SEC will clarify its true intent in this review, as some commentators are suggesting it is the end of this industry. I hope that is not the case as this will further weaken our markets and our economy.