It could be even lower.

I posted on this forum earlier. 3 weeks ago I got an one-day sale email from an Acura dealer in NJ, selling a base MDS around 35-36k range. This is lower than a base BMW 3! 

I don't understand why they are selling MDX at 4-5k below invoice. My guess is that gas mileage and premium requirements are driving the normal Acura buyers away from this car. While I personally think Acura may be as good as BMW, most people who can afford paying for premium fuels are buying German.