Subject: File No. 4-573
From: David W Kent
Affiliation: Member of Association of Cost Engineers, International

October 11, 2008

The mark to market policy reflects the price of Distressed properties and therefore does not account for the value of a bulk or majority of properties or mortgages held by a bank or institution. This gives a distorted view of a portfolio and should not trigger any flags which would inhibit the ability to do business. Fire sale prices are not a true method of determining preforming assets.