Subject: File No. S7-35-11
From: Richard P Whitehill, Ph.D.
Affiliation: University of Ca., Retired Professor of Psychology

September 1, 2011

I think that it erroneous to change the rules regarding mortgage reits as regarding income distribution and tax status.

Doing so would severely reduce the dividend payments of such investments.I believe that concern about investor's understanding of their reit investments is not justified and to use such concern as a basis for negatively impacting both the dividend paying ability and thus the share price of such investments would be grossly unfair to those of us who hold them.

Additionally, in the current investment climate, generous income opportunities are very scarce. For those of us who are retired, they conversely are very important if we are to maintain the basics of our lifestyle, housing, medical care, and other fundamentals.