Subject: File No. 4-573
From: Stephen W Hamilton
Affiliation: none

November 7, 2008

In my opinion one of the largest contributors to the financial crisis is the instution of "Mark to Market" accounting. While on the surface this seems like a good idea to reallisticly state asset values, in this unusual economic times when markets are not in some cases non-existance, this has created artificially low "market values," thus causing in particular Fianancial institutions to de-value their assets so much as to cause panic and insolvency.

I personally have a home that has been on the market for over 1.5 years (the mortgage is current) and have it listed far below replacement value. I know that if I had the resources, it will recover. Fortunately I don't have to report publicly but if I did it would have an unrealistic affect on my balance sheet. If I were a bank, even though the mortgage is being paid, I might be forced to write off to an unrealistic level or even zero in some cases.

I am in favor of repealing this statute. While I agree companies and in particular Banks need to have fair reporting rules the circumstances the country finds itself are highly explosive and the panic is feeding panic without rational review of the impact. Please take into consideration the situation at hand and repeal this "mark to market" regulation.

Kind Regards,