October 22, 2008
The environment that I am witnessing is unprecedented in my over 40 years in the investment business. I have been a security analyst, portfolio manager and hedge fund manager and am a CFA. While the problems in the mortgage market were brought on by greed and stupidity, fair value accounting has provided fuel to this situation. Your recent amendment to fair value accounting is unfortunately insufficient. I believe in full disclosure in financial reports of market value. However, fair value accounting, in my opinion has caused the market values to be much lower than they would be without it. If forced sales are made with no real willing buyers on limited volume, is this really a fair value price? Are all of the prices for securities that trade in the after hours market fair value prices? Please do something to alleviate the problem. Let's stop feeding the fire. I also believe that eliminating the uptick rule was a major mistake. Please bring it back.