Subject: File No. S7-35-11
From: Jeffrey S. Kay, FSA, MAAA, CFA
Affiliation: Fellow of the Society of Actuaries, Chartered Financial Analyst

September 30, 2011

I am curious as to why the SEC is interested in the regulation of REITs. I have been a REIT investor for many years and am not familiar with any problems that would result in individual investors being taken advantage of. REITs are one of the few remaining investment vehicles that offer attractive yeilds in today's market environment. Many REITs use substantial leverage, which brings with it risk that investors should be aware of, but that is no different than the myriad risks that exist in other investment vehicles. Significant restructuring of the regulation of REITs would do nothing but harm individual investors by reducing the number of investment options available to them.

Thank you,
Jeffrey S. Kay