Subject: File No. 4-573
From: brian h tarasuk

October 30, 2008

in the current situation where thereis no effective market for mortgage backed securities an alternitive valuation must be empolyed. inmany cases mortgage pools are 95 precent current but are being priced at 40 cent on the dollar or less.this mark to market has devistated the asset base of our financial system and has contributed dirrectly and indirectly to the failure of teh fnm,fre'leh.this in turn led to panic and the failure of leh. all of this is an unintended consequence of fas 157 which was intended to provide transparency not destroy bank capital base by way of forced liquidation.
an alternative to mark to market accounting would an approach where a cdo which is 95 precent current be valued at 95 minus a hair cut equal to 2 or even 3 times the delinquincy rate and giving no credit for the recovery potential onthe foreclosed properties.this would bring about a quick reversal to normal on the market for mortgage backed securities and calm the markets in general.