At last Monday's SRI Conference, FASB's Ronald Lott, author of FIN 46, responded as follows to inquiries from Marty Rosenblatt, chair of the ASF's accounting committee. These were unofficial tentative answers representing Lott's personal views, and not necessarily those of the board:

* Appendix B should have probably indicated that guarantees of assets were variable interests in the entity only if they related to assets representing a majority of the fair value of the VIE's assets as provided in paragraph 12. *

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