When the Financial Accounting Standards Board (FASB) decided to move forward with changes to FAS 157, Accounting for Fair Value, with the proposed FAS 157-e, "Determining Whether a Market is Not Active and a Transaction is not Distressed," it did so in the face of strongly worded comment letters from the American Institute of Certified Public Accountants (AICPA) and the Center for Audit Quality (CAQ), which expressed serious reservations about the proposed changes. Neither organization supported the draft FASB Staff Position (FSP), and both called for major revisions.