Subject: File No. S7-35-11
From: Daniel A Odell
Affiliation: Retired bond trader and insurance investment advisor

September 3, 2011

If you look at how the mREITs have managed their leveraged funds and compare it to what banks and brokerages have done over the last several years, it is no contest.

Annaly (the oldest and largest of the mREITs) has had a total return, assuming reinvestment of dividends, of 572% since it began in 1997. They have managed to do this in spite of a changing and sometimes difficult interest rate environment. Derivatives and swaps are important hedging tools, not speculations.

With all the shenanigans going on on Wall Street, it seems this area should be near the bottom of a list of potential investigations.

Thanks for your consideration.