Subject: File No. S7-35-11
From: John Mcmillan
Affiliation: Professor of Business Administration

September 2, 2011

mREITs provide important private-sector liquidity to the mortgage market. The SEC should be very careful about upsetting a fledgling housing market by enacting rules whose effects on a fragile economy are largely unknown. The Fed has clearly indicated that they consider private-sector funding of asset-backed securities as critical to a well-functioning financial system, going so far as providing liquidity to banks and other financial institutions for that very purpose. Action by the SEC should not be seen as a dangerous and irresponsible initiative, especially if it ends up disrupting the mortgage market so much that the government has to step in again with taxpayer money.