Subject: File No. S7-35-11
From: Jeff Bronchick, CFA
Affiliation: Chief Investment Officer, Cove Street Capital, LLC

September 19, 2011

I am the lead principal of an SEC registered investment advisor and have specific experience in the REIT format, mortgage backed securities and securitization as well as general economic forecasting.

Let me state this simply: it would absolutely be INANE policy to in any way suggest policies that would severely curtail the abilities of REIT structures to pursue current investment strategies in the mortgage back securities arena. They have developed into crucial links in the housing finance market and to change their structure at THIS juncture in the housing and economic cycle to create a mass selling of MBS securities would be seriously counterproductive to what anyone in government would like to see.

I would also add that unlike a certain pair of government entities, the disclosure of risks and holdings within the majority of MBS REITS is excellent - we know what we are getting.

Jeffrey Bronchick