The recent FSP issued by FASB suggests that expected cash flows should include
appropriate risk-adjusteddiscount rates to reflect credit risk and liquidity risk. In an
inactive and dislocated market, when such premiums may be significant, we believe the
only sellers that would that would accept pricing at these levels would be sellers with no
other options (i.e., forced liquidationsor distressed sales). The injection of severe credit
and liquidity premiums in the determination of fair values contradicts guidance in
paragraph 7, which states that orderly transactions are those which are 'not forced
transactions (for example, a forced liquidation or distressed sale)". We believe
incorporating severe credit and liquidity risk assumptions into the determination of fair
values results in a price that is representativeof a distressed sale, by definition, and thus
does not comply with Paragraph7 of SFAS 157.