Subject: File No. S7-34-11
From: Bob Boyd
Affiliation: investor

September 4, 2011

It is our comment that the SEC make no change to asset-backed issuers as well as real estate investment trusts (REITs) and other mortgage-related pools under the Investment Company Act.

Specifically please remove from your agenda any consideration to change Rule 3a-7, keeping the exclusion of asset-backed securities from having to comply with the requirements of the Investment Company Act.

Thank you.