We strongly disagree with the proposed amendments and the issuance of any standard arising from this Exposure Draft. The proposed amendments create an additional form of purchase accounting with different rules than those for other business combinations. We believe the proposals constitute an unsuitable short-term solution and believe it would be more appropriate to leave the standard unchanged until such time as adequate research into, and resolution of, the accounting issues created by such transactions is completed. We urge the Board to proceed with its project on 'fresh start accounting' as we consider exploration of this possibility may assist in the identification of conceptually robust solutions to this issue.