Subject: File No. S7-35-11
From: edwin hoffman

September 1, 2011

It seems to me that destroying the status of REITs would be harmful in that it would cause considerable financial turmoil and remove a vital source of public funds in the housing market. I regard an investment in REITs totally differently from a mutual fund. REITs have a relatively narrow focus which I am aware of from the prospectus. Mutual funds are generally diversified. I do not need a detailed report of each mortgage paper. The general description of the category is sufficient to evaluate risk. A daily update in REITs is superfluous if there is no material change of categories. In a mutual fund on the other hand, individual holdings relate to different risks and are important to know. A REIT is inherently not diversified and the risks are commensurate as they are in a mutual fund which is not diversified. Investors in REITs are taxed yearly at the full personal tax rate, giving the government greater income than from mutual fund investors who pay capital gains only when the fund disposes assets.