Subject: File No. 4-573
From: MaryAnn Bucalo

November 7, 2008

Dear SEC Directors:

I urge you to uphold mark-to-market accounting, formally known as Statement of Finance Accounting Standard 157, which the SEC has been ordered to review, thanks to the provision added to the $700 billion bailout bill.

Before mark-to-market accounting, companies used undisclosed creative methods for valuing assets and liabilities, which permitted companies to operate recklessly under the illusion that they were financially sound. Mark-to-market accounting eliminated that by creating a standard measure for fair value of assets and liabilities, and thereby enhanced the integrity and transparency of financial statements, which is vital in the current business culture. Credit markets have been frozen for the past 15 months largely because banks havenít trusted the balance sheets of other bank, and therefore, have been afraid to lend to them. Repealing mark-to-market accounting will exacerbate, not resolve, the confidence problems in balance sheets.

Had it not been for Bear Sternsís and AIGís reckless and irresponsible operations, the economic crisis would not have occurred, and the $700 billion bailout bill would not have been necessary.

Please support the FASB and uphold SFAS 157.

Thank you very much for your consideration.

Respectfully submitted,


MaryAnn Bucalo