Subject: File No. S7-35-11
From: Roger H Lewis

September 15, 2011

I've read the prospectuses of the mortgage REITs and their risks are clearly spelled out. They are a part of the investment world that I would like to see left the way they are.

As long as the prospectus makes the business model clear (even if the company is highly leveraged and subject to risk from changes in interest rates) and the Annual Reports are honest, I see no need for changes. The SEC already has rules for all types of companies that don't provide proper disclosure.

Unlike Enron, WorldCom, and other companies that vaporized into nothing while claiming to be growing or profitable, REITs are required to pay 90% of their profits as dividends.

If the SEC wants to change the current investment landscape, they'd be better off making ALL companies pay 90% of their profits like REITs do. The Enron scandal, WorldCom and other travesties could never have happened under such rules. Obviously that suggestion is facetious, because growth investors ought to be able to buy the investments they want too. But REIT investors are actually safer from a lot of fraud risk because when a company claims to be profitable they have to put those profits in the investor's pocket.

When it comes to REITs and mortgage based REITs I'm not seeing a problem for the SEC to meddle in, and I fear that any new SEC meddling in REITs would only harm my investments and investment choices.

I don't think I've ever commented to the SEC before, and I know I've never begged them before, but I'm begging you to just leave the REITs alone and spend your time and resources looking for ACTUAL ciminal behavior or ACTUAL dishonesty in the entirety of the investment world.

As far as I'm concerned REITs are "working as intended". And if they aren't working as the government intended, this investor still wishes you'd just leave them alone.