Subject: File No. S7-34-11
From: Robert J Cunningham, III
Affiliation: None

September 5, 2011

" is opportunity to seek public input on whether Commission guidance, and the few staff interpretations regarding the status of mortgage-related pools under the Investment Company Act, should be updated or made more clear and comprehensive."

In short, No. The inherent contradiction is in the "updated and made more clear" while at the same time being more comprehensive. Any resulting update will inevitably be more confusing and the comprehensive overhaul will have many unforeseen and presumably unintended consequences. One of the advantages of no changes over the past couple of decades is that current risks are apparent and this is to the advantage of the individual investor. Changes made usually work to the advantages of the institutional clients despite all rhetoric to the contrary.