Subject: File No. S7-34-11
From: Paul Cicurel

September 16, 2011

The Mortgage-acquiring REIT aimed in your 'concept' provide funds and liquidity to the US mortgage market (which is sorely in need of both), thus reducing costs to homeowners. Further, they are well-managed and do not seem to require additional regulation that would reduce their ability to function and be attractive to investors. Maybe the SEC should turn its attention to the real problems in the financial world rather than seeking out problems where there are none?