G20 summit - Part VI (the next accounting scandal is on us)
By Denis on Thursday 19 March 2009, 22:11 - Permalink
A crisis does not stop existing because you stop reporting it...
Fair-value accounting has been under constant fire by the Financial Services industry since the beginning of the crisis, mostly on the basis that marking accounts at market prices was too conservative when the aforesaid prices were the result of panic selling.
While this embeds some truth, I already argued (G20 - part III, December 17th 2008) that
panic prices should already be handled (excluded) appropriately with today's
accounting standards, should the auditors, accountants and regulators buy
themselves a back bone and exercise judgement rather than tick the boxes. The
FASB just suggested the same point of view, with a politically-correct wording,
in guidance (called FASB Staff Position) FSP FAS 157-e (March 17th 2009).
Other suggestions might be legitimate and could be a topic during the coming
G20. However, one alternative suggestion (now official by the same standard
body, that vehemently promoted fair-value until recently) should be clearly
excluded: mark to acquisition price. This is in essence what
FSP FAS 115-a,
FAS 124-a, and EITF 99-20-b (March 17th 2009) proposes: if a company claims
it plans to keep an asset for the long-term and claims it is more likely than
not that it will be able to do so (i.e. will not have to sell
it), then the losses on that asset will suddenly be buried under "impairment
related to credit losses" and "impairment related to all other factors" (!).
Might as well say goodbye to the transparency that fair-valuation was meant to
bring. It is worth praising MM. Linsmeier and Siegel, who did not support the
issuance of such FSB (their reasons are mentioned p.8 of the document linked),
for good reasons.
Although avoiding the pro-cyclicality of fair-valuation might be desirable, abandoning fair-value is not a solution. An Economic Cycle Reserve, as suggested by the FSA (see previous post), would be explicit and transparent. Even if the computation of such reserve could be debatable, having a specific item in the accounts is quite different from including it into a bunch of "impairments related to all other factors." Let's hope the politicians will not give in the temptation of reassuring populations cheaply by hiding rather than solving the difficulties.
Comments
April 3rd 2009: on FSP FAS 115-a, FAS 124-a, and EITF 99-20-b,
Recognition and Presentation of Other-Than-Temporary Impairments,
the Board decided that the FSP will be effective for interim and annual periods
ending after June 15, 2009, with early adoption permitted for periods ending
after March 15, 2009.
That is: manipulation can start retro-actively from the 1st quarter of this year! Analysts say the measure may reduce banks’ writedowns ("by up to 70%") and boost their first-quarter net income ("by 20% or more"). American banks quickly issued internal statements that the new standard would not substantially impact their results reported in a few days... but that they are pleased. Anyone guessing why they're pleased? It is obvious they won't show the extent of the new opacity brutally and thus risk a reversal of the decision, but increased opacity is now a reality.
Funnily enough, now European banks are not necessarily as pleased as Americans (as reported
here), because their accounting
standard is not guided by the FASB but by the IASB. The International
Accounting Standards Board is reviewing how financial instruments are accounted
for... but the draft will need a few more months to get ready. As accounting
bodies tended to make their standards converge toward each other for the last
years, this is both a source of worry and an opportunity to set things back
straight.
Following the
decisions of the
FASB board, the proposals are no longer... proposals and the above links are no
longer working.
A copy of the notice for recipients of FSP FAS 157-e is still available, although not at the FASB site (which is a shame). Many thanks to
Deloitte. FAS 157 officially became
FSP FAS 157-4.
A copy of the notice for recipients of FSP FAS 115-a, FAS 124-a, and EITF 99-20-b is still available, although not at the FASB site (which is a shame). Many thanks to
Deloitte. FAS 115
and 124 officially became
FSP FAS 115-2 and FAS 124-2.