Subject: File No. 4-573
From: Urs P. Fischer
Affiliation: Economist

November 6, 2008

Dear Sirs,
it is quite interesting, that we see only very few comments about the positive impacts markt-to-market had on the bank and public companies results before the so-called subprime crisis broke out. Similarly nobody highlights today the favorable impact of downgrades by rating agencies on the value of liabilities, debt and corresponding non-realized profits made by many banks.
In order to avoid this going forward a prudence rule should be added, which existed in IAS before IFRS started to align with US-GAAP:
Asets and liabilities are to be accounted at market (mark-to-market) or cost, whichever is lower.