Subject: File No. 4-573
From: James R Vetter
Affiliation: C.P.A.

October 21, 2008

The current standard for 'Mark to Market' accounting, also known as 'Fair Value Accounting' is flawed in that it forces companies to record entries in their financial statements that are theoretical in both value and result. That is, the decision of whether to sell or retain assets depending on their value is assumed based on the classification of the financial asset (Hold, Trade, Available for Sale) with movement among classes highly discouraged. The consequences of forcing such valuations through the financial statements only serves to further distance the historical fact of what has occurred, as previously recorded, from what will occur once it actually happens.

Rather than attempting to get inside the head of individual business owners and managers by classifying intent based on current perceived values, it seems that the rules should be simplified infavor of actual economic events, not assumed theoretical outcomes.

I propose that companies record assets at amortized cost and impairments be recorded only when they are obviously permanent. Disclosure of estimated current values should be pushed into the footnotes.

While it may seem like an oversimplification, this uncomplicated approach would yield a more meaningful and useable result for all concerned. Those financial statement users that are most concerned with current fair values can gleen such information from the footnotes and adjust accordingly.

Thank you