Subject: File No. S7-35-11
From: M.A. HIGGINS
Affiliation: INVESTOR, M.B.A.

September 8, 2011

Dear SEC Committee,

I wish to go on record stating that I agree completely w/the comments made on Sept. 7, 2011, by Mr. Meszaras (individual) and Mr. Christ of Wedbush Securities.

PLEASE LEAVE THE TREATMENT OF REIT'S "AS IS."

FOR INVESTORS: REIT's are one investment vehicle that is working in a very difficult Market environment. Pls. do not change their status in any way.

FOR THE COMPANIES: They have been operating under certain rules...any change will, at a minimum, require legal and administrative review on their parts...costing money and resources that could be better utilized elsewhere.

Thank you for the opportunity to comment.

Again, please do not change the Status Quo.

Respectfully submitted,

M.A. (Mary Ann) Higgins
Kihei, Maui, Hawaii