Subject: File No. 4-573
From: Timothy L. Baldwin
Affiliation: Emile Banks & Associates

October 8, 2008

Market fluctuation will not change unless the CDO securities are more reliable very much like today’s stock prices. This must be done in order for investor to be more confident in the financial market and to sure up the market:

1. CDO must be valued in two tiers; first, the underlining housing asset must be based on a objective standard, second, the CDO must reflect a securities trading value.

The first, underlining house value can no long be based on independent appraisal values with no standards. Appraiser must now value home as a 'base value' on historical cost or replacement value the after the appropriate depreciating account period. Appraiser, may then adjust that value by index rates for neighborhood comparable rates (NCR), neighborhood redevelopment rates (NRR) and location neighborhood rates (LNR)
1.NCR--will factor in an equalize rate for comparable home in the neighborhood.
2.NRR--will factor in home that may be in re-emerging neighborhoods.
3.LNR--will factor in community values based on housing values and location.

The second component requires an objective standard for a market price on the mortgage paper terms.

1. The CDO can not only consider the underlining values of the asset, the CDO also has a market value for the terms of the mortgage for the cost of money. That value includes interest rate values and the structured payments.

If these objective standard are implemented the accounting standard and properly disclosure under securities regulation then the market value on these instrument will be secured up.

Timothy L. Baldwin
Emile Banks & Associates
High Pointe, Suite 290
1200 North Mayfair Road
Milwaukee, WI 53226