Subject: File No. S7-34-11
From: Michael S Maher
Affiliation: Financial Blogger

September 2, 2011

I think it would be unwise to change the way mREITs are allowed to conduct business. It adds unnecessary regulatory risks to an asset class that is performing well, has been stable, and offers investors high yields. In addition, adding any uncertainty to the business could cause strains in the secondary mortgage market, which would have adverse affects on other participants in that market.