Subject: File No. 4-573
From: Roger W Jeremiah
Affiliation: Lifetime commercial banker

October 30, 2008

While I applaud the transparency intent of mark to market accounting rules, I believe the entire concept exists solely for the benefit of short term traders and inhibits a company's ability to invest and manage for the long term. While not the cause of the current crisis in financial markets, the rules have certainly contributed to greater volatility at a time when stability was the required tonic.

I urge you to consider that, while theory is fine in a sterile environment, all rules and regulations must work in the real world and I believe this is an example of one theory that does not work. A much more balanced approach is warranted where the interests of all affected parties are given comparable weight.

You will certainly receive some very detailed input on this issue from some incredibly bright people who can support their arguments with highly sophisticated thinking. I would suggest that in your final analysis, you take a very big step back from the entire discussion to look at the forest instead of the trees. In doing so, I think you will agree with me that mark to market accounting makes no sense under any circumstances except those where a company is in the process of being liquidated or said another wey, in a society where there is no tomorrow.