Subject: File No. 4-573
From: Dan Steward, CPA

October 24, 2008

I think the study is a great idea. I strongly believe that fair-value reporting opens the door for earnings management and manipulation for large public companies, error and excessive cost for smaller public companies and private companies with little to no additional value to their shareholders, and additional audit complexities and risks to audit firms having to opine on fair-value measurements.

I think we are allowing a select group of financial users dictate their needs and wants. In their opinion, the information may be more relevant, but I believe the cost outweighs the benefit because the information is less reliable and harder to opine on.

Although I understand many arguments of a select group of users of financial statements that believe that fair-value reporting is more relevant financial information, from an auditor's perspective, we are moving more close to every balance being a significant estimate subject to more management estimation and potential bias.

I think the standards should allow more flexibility in fair-value presentation. Permit, but don't require, supplemental financial information presented in fair-value. If investors of certain companies want this information, then they will require it. If this is the case, I beleive that the supplemental information should be unaudited. Fair-value measurements are an art not a science. No matter what an audit firm does, offering an opinion on fair-value measurements is such a subjective process that I am not sure how reliable that opinion really is.

The FASB is getting to a point where the needs of financial users of large public companies are driving accounting for everyone. I don't think this is the right approach to standard setting. Cost-benefit analysis should consider all companies, large or small, public or private, before issuing standards.