Subject: File No. S7-33-11
From: Dwight E Fisher

September 1, 2011

As an investor in reits I am glad to see that the SEC is involved in the oversight on these securities. If accounting practices are to be standardized I can only see this as beneficial to the public. I only worry over redefining the status of these companies and the possible loss of revenue caused by restructuring or changing the class of investments they may be able to acquire.