On December 30, 2008 the Securities and Exchange Commission released the SEC Report to Congress on Mark-to-Market Accounting. This report, as widely anticipated, recommended against a suspension of Statement of Financial Accounting Standard Number 157, Fair Value Measurements (“SFAS No. 157”). Additionally, the report recommended against a suspension of existing mark-to-market and fair value requirements.

Their rationale for both recommendations was quite simple. SFAS No. 157 does not require any additional fair value measurements, although it does provide for a common definition of fair value and require enhanced disclosures regarding fair value measurements. Suspension of this standard, in the opinion of the SEC, would simply permit companies to revert to the utilization of many various definitions of fair value measurements and eliminate financial statement transparency that financial statement users are calling for. This bring potentially negative consequences during times of economic uncertainty such as the present. Furthermore, the SEC believes that a suspension of any existing fair value requirements under various other standards would also erode investor confidence as these requirements "were developed over several decades, in some cases to specifically address perceived weaknesses as a result of prior challenging market conditions or events." Additionally, statistical evidence was cited to suggest that the current financial crisis was not exaggerated due to fair value measurements. The "study indicated that, on average, approximately 50% of broker-dealer, 22% of bank, 7% of GSE, 3% of insurance company, and 1% of credit institutions are marked-to-market." In other words, very few of the assets held by financial institutions are actually subjected to mark-to-market requirements, and the capital of failed banks had been minimally impacted due to fair-value adjustments.

However, while the SEC did not recommend a suspension of SFAS No. 157 or existing mark-to-market requirements, they did suggest several recommendations for improvement.