Subject: File No. S7-34-11
From: robert cioffari
Affiliation: cpa

September 1, 2011

Very bad idea. A drastic change in the rules devastates investor confidence. The reits are helping the housing industry when they are in crisis. They give retirees dividend income when there is no other place for them to go. The rating agencies have proven to everyone that they are a sham, in it only for their personal gain and greed. This is a ridiculous idea. Squash it