Subject: File No. 4-573
From: Susan M Saidens, CPA, ABV, ASA, CVA, CFE, CFF
Affiliation: AICPA, PICPA, ASA, NACVA, ACFE

October 22, 2008

The real issue with Mark to Market accounting is that the revised definition of "fair value" in SFAS 157 is inappropriate. The idea of using an "exit" price is wrong, and everything follows from that. The definition of "fair value" in SFAS 157 should be changed.