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On August 31, 2011, the United States Securities and Exchange Commission (SEC), in Release No. IC-29778 (Release), provides a concept release and requests public comments regarding mortgage-related pools, including certain real estate investment trusts (REITs) and issuers of mortgage-backed securities, that rely on the exclusion under Section 3(c)(5)(C) of the Investment Company Act of 1940 (ICA or 40 Act
