Subject: File No. S7-34-11
From: Stephen C Benine

September 14, 2011

To whom it may concern,

This is to urge you not to change the regulations governing REITS such as Hatteras Financial Corp. and American Capital Agency.

REITs own about $200Bn of agency MBS and their presence in the market in their current form benefits a wide segment of society including homeowners, MBS market participants, and equity investors. A dramatic reduction in REIT leverage would have an adverse impact on these groups and would be very disruptive to the market for MBS and create a headwind to housing policy in the US and further slow a housing recovery. This is not the time to be causing added problems in housing.

I am retired after spending more than forty years in mortgage banking and commercial lending and this strikes me as the SEC looking to blame someone other than ill-run organizations such as FNMA and FHLMC. for government loses.


Stephen Benine
Seattle, WA.