Subject: File number 4-573

December 10, 2008

Dear Chief Accountant:

It is clear that dysfunction in global capital markets is making almost all securities in the fixed income area subject too "unfair" fair values. Now is the time to go further is suspending "fair value" accounting since it is adding to the pressures on global financial intermediaries. The current markets are driven more by fear than underlying fundamentals behind these securities. Something should be done to address the accounting for debt securities before year-end financial statements.