While Congress and the White House consider next steps for the bailout package for Wall Street, the Treasury and its fellow regulators should follow their own counsel and take without delay the one regulatory action within their discretion that can help immediately to calm markets and dramatically reduce the taxpayer risk in any necessary government intervention: suspend mark-to-market.

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dick schroeder --I recently completed a study of the effects of 157-4 on the 73 banks in the Russell 300. The findingswerethan its adoption wasdessentially irrelevent. That is, only 4 of the 73 banks reported amaterial impact from the adoption of 157-4 eitheron theearly adoption date of March 31, 2009 or the required adoption date of June 30, 2009. Anyone have thoughts on why this might have happeneded given that both opponents andsupporters of 157-4 expected a large increasein reported earning upon adoption.
2009-08-30

Amy Lee --My post-science teacher Dr. Hugh Ching (also MIT 65 66 70) wrote the following regarding Mark-to-Market standard. Basically, he believes that irrational market participants determine wrong market prices, which are the causes of financial crises. Thank you for your consideration. sincerely, Amy Subject: The Market Price Is Wrong! The financial crisis occurs because the market price is wrong. Market participants using incorrect method of valuation will produce an incorrect market price. The market price will be correct when all the market participants, including, particularly, the government use the correct solution of value. However, the current market price is determined by incorrect solution of value. The most common incorrect solution of value is the market comparison approach. It? role in the financial crisis can be explained by the parable that "The blind follows the blind, until everyone falls off a cliff." In theory, the price depends on the future expectation, not the past market price, which can be used only when future expectation has not changed, but future expectation will continually to change to infinity in time. The correct solution of value uses an income approach where the inputs to the valuation system are obtained from market comparison. Only the price should not be compared to past prices; the price depends on the future income. The mathematically rigorous solution of value is disclosed in the patent "Quantitative Supply And Demand Model Based On Infinite Spreadsheet" (Pat. No. 6,078,901). The calculated price based on the solution of value is generally different from the market price, which oscillates around the calculated price. The solution of value predicted the Savings and Loan Crisis publicly as early as 1984 when the market price became over-valued where the market price was appreciably greater than the calculated price. It predicted the Subprime Woe and warned the Federal Reserve in June of 2006 that the rising interest was approaching the decreasing, due to the increasing interest rate, investment rate of return, which should be greater than the interest rate in order for investors to borrow. Even being wrong, the market price is the main hindrance to the public acceptance of the correct solution of value. The textbook definition of the market price that the price is what a buyer is willing to pay is only correct if the buyer is using a correct solution of value. During the Savings and Loan Crisis, nearly all the real estate appraisal authorities endorsed the correct solution of value and abandoned the three traditional approaches to appraisal, but the Crisis was solved politically with over 0 billion of money from the taxpayer. Being mathematically rigorous, the solution of value is a non-violable law of nature in social science. Only mathematics can expose our blind faith in the market price. Nature is trying to teach us the non-violable law of nature, namely, the solution of value by punishing us with repeated financial crises. If we still refuse to replace the mark-to-market standard of accounting with the solution of value, admittedly a revolutionary change, we would again suffered in vain in the current financial crisis. 2/11/2009
2009-03-05

Tim Law
2009-03-04

Brian Davies
2009-03-01

Steve Bumann
2009-02-24

Timothy Weir --Instead of spending trillions of dollars we don't have and forcing future generations of tax payers to shoulder the bill, why not suspend mark to market accounting rules which costs no money. Why should a loan be considered bad if payments are always paid on time but the value of the asset temporarily declined? It's hard to believe that we would rather spend trillions of tax dollars in bailouts, stimulus, and buying "bad loans" rather than change one accounting rule. Didn't both election campaigns promise tax reforms? Here's your chance.
2009-02-23

Brian Perry --FAS 115 Other Than Temporary Impairment is the rule we follow to write down an impaired (less than book value) asset if the asset's value is other than temporarily impaired. First we have to agree on how to value the asset. In a distressed market there are many interpretations to arrive at this value. Second, what value should be considered OTTI? Market values change frequently and can improve in value just as quickly as decline in value. OTTI, however, is a permanent adjustment. There is no option to write the value back up if the asset value improves at a later time. ABA President & CEO ED Yingling suggests that "the trigger for determining OTTI in the United States should be based on actual credit impairment, and the accompanying markdown should be made for the amount of that credit impairment as opposed to marking it to market.” Do you support or reject this concept?
2009-02-19

Martin Carpenter
2009-02-12

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2009-02-12

George Darling
2009-02-11