Subject: File No. S7-34-11
From: Gerald L Ritter
Affiliation: Retired DOD Budget Analyst and Logistician

September 20, 2011

The existence of mortgage REITS is a great benefit to both the real estate market and to investors. The amount of leverage they maintain is miniscule compared to banks. Also, REITs have in many cases hedged so that they have a lower risk.

The crisis in the housing market is the result of foolishness, greed and very bad management, esp. in the Federal Agencies that were suppposed to be a stabilizing factor. Mortgage REITS have held up better than the culprits in this debacle, the banks, realtors, and federal agencies. Reits are still doing better than the market and provide some income to those of us being squeezed by various inflationary factors which the CPI ignores.

Please do not cause more pain with changes that might have unintended consequences.

Thank you.