Subject: File No. S7-34-11
From: Bill Stokes

September 8, 2011

After your announcement of August 31 the mREIT market has been under pressure with high volatility. Articles published in respected publications have indicated the the mREITs will have to choose between leverage and taxation. This as you know will in effect end the mREITs as we know it and cause the loss of millions to investors, both retail and institutions alike. An that's doesn't even cover the loss of income to investors, many of which are retired and need the cash flow. What purpose can you achieve by doing this but cause market turmoil and heart ache? If your purpose is to just improve oversight then you should have made that clear in your announcement for comments and thus avoided all this speculation. It's likely you've already caused people to sell at a loss due to the speculation.

Bill Stokes