Subject: File No. S7-14-11
From: John W O'Brien
Affiliation: Managing Partner, Home Equity Securities LLC

July 29, 2011

Comments attached

Home Equity Securities LLC is pleased to offer the attached Comment on Credit Risk Retention, Qualified Residential Mortgages, Sources of Down Payment, Request for Comment number 121, page 24124. Our comment addresses the use of equity sharing to expand the availability of the QRM without lowering its very high credit quality.

I have discussed equity sharing as a partial source of down payment with each of the Agencies, either in person or by phone.

Also, I have discussed with leaders of the Congress the issue of shared equity as an important new component of home finance, both for more effective mortgage modifications and for partial down payment assistance in home purchase transactions. Their response has been uniformly positive.

If you would like further elaboration on our Comment or access to the rigorous modeling supporting our position, we will happily oblige. I look forward to hearing your response to our Comment.

Very truly yours,