Subject: File No. S7-34-11
From: Paul D Wallace Jr, JD MBA CFA
Affiliation: FL, PA, MA Bars CFA Institute

September 1, 2011

Requiring MREITS to register under the Investment Company Act would put an end to the business model and would increase mortgage rates by virture of decreasing the numbers and buying power of holders of mortgage backed securities.

Without evidence of fraudulent actions on the part of MREITS, what public purpose would be served by seeking to regulate these entities as registered investment companies? In fact the economic costs of such regulation would far outweigh any presumed benefits. This also could not be a worse time to announce this as something the Commission is considering. It, also, based on the market reaction this morning, is costing millions of MREIT investors dearly needed savings and income. Simply horrible timing and lacking in practical sense.