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Get July 17, 2009 Mr. Russell Golden Technical Director Financial - REITs

N Paper. These more granular issues raised by NAREIT members reinforce the view that accounting by lessors of investment property would be more effectively developed separately outside of the Leases Project. If the Board or its staff would like to discuss NAREIT s views as expressed in this comment letter, please do not hesitate to contact George Yungmann at gyungmann nareit.com or (202) 739-9432 or Sally Glenn at sglenn nareit.com or (202) 739-9442. Respe.

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