SEC Recommendations on Mark-To-Market Accounting #2

Existing fair value and mark-to-market requirements should not be suspended.

Observations:

- Fair value and mark-to-market accounting has been in place for years and abruptly removing it would erode investor confidence in financial statements.

- Fair value and mark-to-market accounting do not appear to be the “cause” of bank and other financial institution failures.

- Mark-to-market accounting is generally limited to investments held for trading purposes and for certain derivative instruments; for many financial institutions, these represent a minority of their total investment portfolio.