Subject: File No. 265-24
From: Roberto Viana, CPA
Affiliation: Director of SEC Reporting, Prime Income Asset Management

June 17, 2008

What if anything is being done to address the conceptual frame work? It would appear as if there is a shift from the income statement to the balance sheet. Currently, EPS is the big number that investors seem to rely on. With the shift to fair value accounting, EPS would seem less relavent. In addition, the current accounting standards models have various valuation methods for various assets, such as: Cost basis, amortized cost, lower of cost or market, and fair value, to name a few methods. This is confusing. In addition, the new standards contradict the old standards FAS 115, contradicts with FAS 157 159. Or can we use both in combination?

In summary it would appear as if we are in the middle of shifting the conceptual frame work. Yet, I fail to see where this is addressed. I would think that you'd want to set the conceptual frame work in stone(somewhat) and then build off of that. If it is fair value, then build a model off of that. Then, set standards around the model. Currently, all I see is a push towards IFRS, and no End Goal?

I'd like to use COSO as an example. They set up an "internal control framework or Model" and then based their work around that. Shouldn't the financial accounting world do the same?

The most recently released accounting standards seem vague and somewhat confusing as to their application, where and how it applies. Although I understand principal base accounting, I do not understand the need to be vague?