Subject: File No. S7-35-11
From: derek eichert, mr

October 3, 2011

Individuals pay income taxes on dividends they receive from reits. The reits should not have to pay a tax on the front end of the earnings they receive from their investments in mortgages. The better reits invest in government backed mortgages like fannie mae,gennie mae and freddie mac and should be allowed higher debt to equity ratios. These investments are safe.
Thanks for allowing these comments
Derek