Subject: File No. S7-35-11
From: Lee R Donais
Affiliation: Investment Officer, L.R. Donais Company Inc.

September 2, 2011

The treatment of asset backed issuers under the investment company act of 1940 has worked properly for the past 71 years and at the current time poses no problems to the the investment community. To even contemplate changing the tax status and/or put these companies in the same class as mutual funds is not only ludicrous but a complete waste of time on the part of the SEC.