http://www.sec.gov/spotlight/fairvalue.htm understates the realizable future benefits from the assets over a longer time frame, and induces the issuer to take dramatic steps to meet capital requirements. These steps would be suboptimal in the absence of the SEC/FASB guidelines. I recommend a compromise between the opposing views. My recommendation is based on three assumptions. First, the fundamental goal is to ensure satisfactory disclosure %G�%@ disclosure that is clear, complete, timely, and accurate. This goal supports continuation of the SEC/FASB guidelines. Second, substance is more important than form. By substance, I mean the asset value information that is produced by implementing the SEC/FASB guidelines. This information could be disclosed to users in various ways,