Subject: File No. 4-573
From: David Cox
Affiliation: President, The Bradbury Co., Inc.

October 28, 2008

File reference: File No. 4-573 Fair Value Accounting

I have watched with dismay over the last month as our financial institutions have systematically imploded. This is having a negative effect on the global economy which is accelerating, at an alarming rate, to affect businesses worldwide in virtually every industry.

At the heart of this failure is the financial institutions which had capital requirements which could not be fulfilled in todays environment. Many of these institutions had capital requirements forced upon them due to the SEC and Statement 157 Mark to Market Accounting Rules.

Mark to market violates every logical decision of a going concern business with a view to the future. If you own assets which you intend to hold to maturity and you would only sell those assets in a situation where you are a willing seller and you find a willing buyer to agree on your price, then the failure of mark to market is the requirement to mark down the assets in value at a time when you are not a willing seller and have no intent to sell at prevailing market prices. Compelling these businesses to write down the value of assets and therefore requiring them to raise capital to offset the write downs of an asset which they have not intended to sell has magnified the crisis we are in today.

To take this ill founded logic a step further, one only has to look at the current plan to solidify the capital markets. Our government has now come forth with a plan to buy the distressed assets, those assets being the ones impaired and arbitrarily written down in value only to hold those assets for a period of time until the values come back and the government can exit their investment at time when taxpayers will not lose money on the transaction and get their tax dollars back.

Why, then, would you force a business to write down asset values when the solution itself is to hold the assets until a time when the market conditions allow the assets to be sold at a higher price than todays stressed market environment would allow?

Back in my college days, when I was an accounting student, one of the fundamentals to accounting philosophy which was taught is the matching principle that being the matching of revenues to expenses. We should not force businesses to write down assets to an impaired value when the very asset in question has not been sold, has no intention of being sold and, therefore, is not generating any change in revenue or expense.

The solution is to suspend the requirements of Statement 157 for mark to market accounting immediately by the SEC, repeal of this Statement by FASB and for Congress to remain on the sidelines and out of the way so they do not impede the process.

Thank you for allowing me to voice my input.


David Cox
The Bradbury Co., Inc.