The Dealer Accounting Committee of SIFMA provides comments to the Financial Accounting Standards Board (FASB) on a proposed FASB Staff Position that would delay indefinitely the effective date of American Institute of Certified Public Accountants (AICPA) Statement of Position 07-1, Clarification of the Scope of the Audit and Accounting Guide-Investment Companies and Accounting by Parent Companies and Equity Method Investors for Investments in Investment Companies, File Reference: Proposed FSP SOP 07-1-a.  SIFMA believes the net impact of SOP 07-1 would be “less fair value reporting in situations where the business is clearly better suited for a fair value model.”