Subject: File No. 265-24
From: richard solomon
Affiliation: self employed investor and manager of funds

June 26, 2008

It is necessary for the SEC and the FASB to join forces and adjust mark to the market accounting so as to provide the reader a balance sheet and income statement that is logical and reliable of what the results from business operations have been covering the qtr and or year, In addition the valuing of assets needs to be qualitatively done so as to present a picture of long term assets and assets available for sale and trading assets that is comprehensive and understandable by investors and lenders.

I am 52 years old and have been reading financial statements since I was 10.
The complexity that now exists in the reading of many a large corpporate balance sheet is intimadating and frustrating.

It isnt good enough to leave things as they are. The marking down CDO and MBS and other long lived assets is too prblematic to the system that in the current environment no one is going to be willing to allow for material changes.

I believe that a bank of Citibank, is so larage that the Federal Rserve cant afford to let it fail. Therefore to hold Ciibank to a standard of accoutning marking to market will enure to needing more and more capital to be raised.

On a case by case basis the SEC needs to get invloved and understand the plan a Company like Citibank has for holding assets that are in a state of falling market values. The SEC needs to be able to bend the rules to help corporations avoid raising un needed capital