Subject: File No. 4-573
From: Peter Quigley
Affiliation: Managing Member Renvyle Partners, LLC

November 19, 2008

Mark to Market valuation is useless and dangerous in an illiquid market.

It should be suspended immediately for a year or more while new rules that both protect investors and don't endanger the financial system are drawn up and enacted.

Unfortunately, this rule has greatly contributed to the ongoing destruction of our economy.

Thank you,

Peter Quigley