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FASB Staff Draft: "Fair Value Measurements"

Wednesday, November 16, 2005

The Financial Reporting Committee is writing to provide fatal flaw comments on the Staff Draft on Fair Value Measurements, which was recently posted to the FASB website. We see several significant issues related to the Staff Draft. We have attached our prior letter that outlines our significant concerns regarding the marketplace participants approach. We also have concerns with new guidance added after the issuance of the Exposure Draft that relate to transaction costs and proposed disclosures. Each of these matters is discussed below.

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