Subject: File No. S7-35-11
From: Jim Clarke

September 9, 2011

Changing the leverage rules effecting mREITs would decimate their dividends and their share values, wiping out thousands of investors, and adding random regulatory uncertainty to an already jittery market.

Aside from harming individual investors in mREITs, changing leverage rules on mREITs would reduce a huge source of financing for the housing market. Is that a wise choice given the highly depressed nature of the housing market which is one of the main, if not the main, overhangs that is holding our economy back?

In short this proposal would
1) decimate individual investor's portfolios arbitrarily.
2) cause retirees to lose their dividend incomes at exactly the time when they need that security the most.
3) reduce an avenue of financing for the housing market exactly when the housing market is at depression levels, and badly in need of capital formation.

I can't think of any benefits of this proposal.

mREITs have been providing steady and consistent returns for investors for more than a decade which is saying something considering the 2 massive bubbles, and other turmoil that has ravaged the financial markets during that time.

Please don't take away this invest vehicle.