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March 11, 2009

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James Burnham

Bill, let's make a distinction between accounting for regulatory purposes and for investor disclosure. It's the regulators at this point who are insisting, using mark to market accounting, that the banks get more capital. If a bank can make a credible case for not using mark to mark, it should be allowed to do so - for regulatory purposes. At the same time, it may want to also use mark-to-market if investors demand it.

Primus Guaranty, the credit default insurance company, was showing a $1.8 billion negative shareholders equity at the end of 2008, based on mark to market. But it intends to hold these positions to maturity and has substantial reserves to cover prospective losses. Fortunately, they are not regulated by the U.S. government, and I continue to hold a modest profitable position in both their common and preferred.

Bill Burnham

I disagree. The "Ostrich Strategy" of simply ignoring market values is far worse than marking to market. What about investors and counterparties? Don't they deserve a realistic view of the bank's current balance sheet? Shared denial and opacity is not a strategy, it's a suicide pact.

Mark to market at least makes an attempt to give investors and counterparties as realistic a view as possible of the current state of a financial institution. But perhaps most importantly, mark-to-market puts pressure on institutions to change. It is the schumpeter-esque destructive force that destroys fundamentally badly managed and or structured institutions (e.g. Citicorp). The Ostrich Strategy just gives a free pass to poorly managed institutions.

The solution is not to ignore reality and let badly managed institutions live on, but to construct a system that allows institutions to fail gracefully no matter how big they are.

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