Subject: File No. S7-35-11
From: Tom Chorba

September 1, 2011

The mortgage REITS are providing a vital function in the post-financial crisis. Banks are trying to limit mortgage exposure to improve balance sheets. Fannie Mae and Freddie Mac already have too much mortgage asset exposure. Further, we don't need the U.S. government as the only (or majority) mortgage lender. Therefore, these REITS have moved in a space to take varying types of mortgage risks. They seem to be developing a greater space in the mortgage market. This is is a great vehicle to re-distribute risk exposure with smart capital.

In many ways, mortgage REITS are simply savings and loans without the bricks and mortars associated with those banks.