Subject: File No. S7-35-11
From: S M Raihan

September 8, 2011

1. REIT in general should not be subject of Investment Act for the purpose of leverage.
2. leverage ratio can be limited to 10x though. And the size of initial market capitalization and subsequent issue of stocks also could be limited to 5 billion USD.
3. Underlying security should also be open to SP 1000 and not just Asset or real estate.