October 10, 2008From: Roundy, Blaine Sent: Thursday, October 16, 2008 2:30 PM To: Rule-Comments Subject: file #4-573 (sn# 29) The attached comment was sent directly to OCA and should be posted to file number 4-573. -----Original Message----- From: Mark Haslem [mailto:firstname.lastname@example.org] Sent: Saturday, October 11, 2008 10:34 PM To: OCA Subject: Please act quickly
Dear Chief Accountant: Please act quickly to help deal with this liquidity crisis. Mark to market has got to go, the bond markets are in complete disarray, the prices are not a good reflection of the underlying value. Banks should be able to state the value based on a conservative but reasonable valuation method that uses the income stream of the bonds/mortgage instruments. I think everyone would accept that. It's a very reasonable thing to do. You and the FASB should act fast and announce new changes ASAP. Another thing that would help a great deal is on some of the laws that were passed after the enron scandal had a great deal of criminal penalties involved for misstating the financial picture. Accountants ever since have been terrified that they haven't been conservative enough in their estimates. They should be made to know that there will be a certain amount of leeway in the law for the new valuations unless they obviously mistate or intentionally mislead. The truth is banks have been worried about that ever since, there are plenty of banks out there that are in a perfectly sound situation and yet they are completely panicked about insovency based on the commercial paper collapse. If they were allowed to figure out their book value on a more reasonable basis than on the prices of a marketplace that isn't functioning then lo and behold guess what a number of them will find that they have plenty of cushion. This would do more to unfreeze the banking paralysis than the grandiose schemes that Treasury is cooking up at the moment. Please act quickly we need this now!