SEC Recommendations on Mark-To-Market Accounting #1

SFAS No. 157 [the standard that defines fair value accounting] should be improved, but not suspended.

Observations:

- The guidance in SFAS No. 157 does not determine when fair value should be applied. SFAS No. 157 only provides a common definition of fair value and a common framework for its application.

- Suspending SFAS No. 157 itself would only revert practice to inconsistent and sometimes conflicting guidance on fair value measurements.

- Other recommendations address necessary improvements to existing standards.