1810-100
Comment Letter No. 401
From:
To:
Subject:
Date:
Douglas Ott
Director - FASB
File Reference No. 1810-100.
Friday, September 10, 2010 2:52:54 PM
I have read many articles over the past few years regarding the proposal on Mark-to-Market
valuation of accounting for banks. I cannot think of anything which would in all probability close
the majority of small banks. The cost of compliance and the additional work hours needed for
compliance would be staggering. I cannot understand how this would benefit anyone especially
small banks like ourselves who’s ownership is constant and very small.
The most perplexing thought is the economic impact which could be caused in all banks large and
small during economic swing cycles like we are presently in. This would cause banks to stop
lending in times when lending is just what the country needs to get it back to prosperity.
Mark-to-Market is essentially applied to all bank investment portfolios now with good reason, a
portfolio can be a primary source of liquidity in time of need and this information can be helpful for
bank regulators.
I am just a country banker with 38 years of lending and bank operations experience but hope
Mark-to-Market accounting is never applied to the loan portfolio of small banks like ours.