Subject: File No. S7-35-11
From: Canadian Investor

October 11, 2011

As a foreign investor, I invest my savings into MREITs and these are my points:

1) The business model of MREITs is simple and easy to understand. Their holdings are transparent and safe with AAA credit rating. The repayment rate on their mortgage holdings is stable and fully backed by the US Government.

2) The management teams update their book values adequately every quarter. They did their home work well, and hedge against the risk of rising interest rate. They clearly disclose that their leverage ratios are around 4 to 7, which is comparable to a bank.

3) I paid tax to the US Government for every dollar of dividends that I received, and reinvest the rest back into the US economy.

4) Unlike Fannie Mae and Freddie Mac, Ginnie Mae is a government owned corporation that guarantees mortgages that have been guaranteed by the Federal Housing Administration and the Veterans Administration. So even without Fannie and Freddie, MREITs can build their entire portfolios with Ginnie securities.

4) If the rules for MREITs change, many foreign investors like me would sell our holdings and take our money back home.