Subject: File No. S7-35-11
From: Dr. Sheldon S. Ellis

September 14, 2011

Ladies and Gentlemen -

I support the establishment of a clear and
comprehensive set of "Best Practices" for
the operation and management of all mortgage

However, I oppose any set of "Best Practices"
that would, in any way, interfere with or
impede the traditional roles of Mortgage REITs
in capital formation for residential housing,
safeguarding their investors and enabling
Mortage REITs to continue to generate income-
based returns for institutional and retail

Dr. Sheldon S. Ellis