SIFMA’s Dealer Accounting Committee (DAC) provides comments to the Financial Accounting Standards Board (FASB) on whether a market is not active and a transaction is not distressed, Staff Position No. 157-e. SIFMA’s DAC does not support the proposed FASB Staff Position (FSP) in its current form. We are very concerned about the presumption in the proposed FSP that all transactions in inactive markets are associated with distressed transactions unless proven otherwise. We believe this presumption directly contradicts the conceptual framework, where transactions are presumed to have been freely negotiated on an arm’s-length basis. More importantly, it is highly unlikely that each piece of pricing information in the possession of a reporting entity is associated with a distressed transaction.