Subject: File No. S7-35-11
From: Frank Offenbeher

September 7, 2011

I am retired and these M-REITs are the only investment I have made any money from. Institutional investers such as pension funds invest in M-REITs. Taxes are paid at the full dividend rate on dividends paid to investers. I don't think changing the rules for M-REITs in this economy, with pension funds and other investers hurting,is a very bright idea.