Lurker,
I need to read this through a couple of more times to make sure that I fully understand what he is saying. After a quick read through I would say what he is saying is roughly analogous with my thoughts. Mark-To-Market is not in an of itself bad. I have tried to make that point before, but I am sure some of that has been lost in my rants. It is pro-cyclical, so it makes market tops higher, and market bottoms lower. That is its biggest flaw.
My biggest issue with mark-to-market is how it is being applied today.
1.) It is valuing different securities the same. Common shares of Microsoft are all identical so they can be valued the same. 6 month T-Bills are all the same, except interest rates, and that is addressed in the price. No two MBS are the same. They have different risk profiles, different security positions, underlined by different mortgages, in different locales, with different rates of return, and different tranches. You cannot automatically apply the value fetched for one MBS to all other MBS. The underlying securities are not the same. They are basically saying that a share of GM sold for 24 cents today, so you must mark your Microsoft shares to 24 cents. Microsoft shares may have been trading at $32 a share, and this value was determined by a well functioning market projecting expected future earnings, and placing a value on one share related to that.
2.) There is not a well functioning market trading MBS, but you need a "market" to mark the securities to. I agree that the actions taken so far by Bush/Paulson and Obama/Geithner have only made the situation worse. They have created more unknowns, and making promises, and the dithering they have created enormous uncertainty. This uncertainty has lead to paralysis, which has caused the market to wait, and then the only securities that actually get traded are those out of desperation. That then sets the market.
I have heard that Obama's FDIC chief, and Bernanke are loathe to suspend MTM, but are willing to consider modifying its rules, clarifying some, and creating some rules that address the specifics of securities like MBS. I have to wait to see what they actually propose, but if this is where we go then kudo's to them.