Subject: File No. 4-573
From: Betty Meredith, CFA, CFP, CRC
Affiliation: Managing Member, InFRE Retirement Resouce Center

November 7, 2008

Reflecting long term liabilities using short term mark-to-market pricing will create enormous unnecessary fluctuation in an organization's cash flow needs as well as force investors to make adjustments to get an accurate assessment of the actual liability. A three-five year smoothing calculation on funding of long-tern liabilities like pensions is more appropriate for investors, organizations and plan participants.