Wednesday, December 9, 2009

FASB Chairman: Fair Value Not Cause of Crisis; Separate Banking Regulation from Accounting

Journal of Accountancy is monitoring the AICPA SEC PCAOB conference this week.
They report here on a speech by FASB Chairman Robert Herz on Tuesday that addressed head on criticism of the role of accounting standards in the financial crisis and called for GAAP to be “decoupled” from bank regulation.

Herz, speaking at an AICPA conference, contended that many of FASB’s critics simply do not understand its mission. “There seems to be some confusion in the media and elsewhere about the relationship between the accounting standards we set and regulation of financial institutions,” said Herz. He explained that FASB does not determine the capital levels banks are required to maintain, but under laws enacted in the wake of the savings and loan crisis, bank regulators determine regulatory capital caccstarting with GAAP numbers. But bank regulators can adjust the GAAP figures, and they also have other tools to address capital adequacy, liquidity issues, and concentrations of risk at regulated institutions, Herz said.

He said that while FASB has a deep interest in the strength and stability of the financial system and the economy, its public policy mission and focus is designed to be different from that of banking regulators. “Our focus as accounting standard setters is on the communication of relevant, reliable, transparent, timely, and unbiased financial information on corporate performance and financial condition to investors and the capital markets,” he said. “The transparency provided by external financial reports contributes to financial stability by reducing the level of uncertainty in the system—and a lack of transparency can hide the extent of risks facing financial institutions from both investors and regulators.”

The mandate of the Federal Reserve and other banking regulators, according to Herz, differs in that it relates to ensuring the soundness of banks and the overall stability of the financial system. He says most of the time FASB and banking regulators can find common ground, but in some situations they’re actually in conflict. “In dire situations, bank regulators may be appropriately concerned that public release of data on severe losses and asset impairments could spark a run on a bank,” said Herz. “But investors would likely want to know the extent of the problems on a timely basis.”

The answer to this problem, according to Herz, is to “decouple” bank regulation from U.S. GAAP reporting requirements. “Doing so could enhance the ability of both the FASB and the regulators to fulfill our critical mandates,” he said.

And Herz, citing a
1991 GAO report following the S&L crisis, seemed to indicate that he believes that although GAAP and specifically much-criticized fair-value accounting did not cause the financial crisis, a GAAP unencumbered by pressure from banking interests would have done a better job of alerting investors and other stakeholders of an impending crisis. “The [1991] GAO report found that regulatory call reports significantly overstated the values of loans and debt securities (and hence the financial condition and capital) of failed banks,” he said.

He pointed out that the stress tests banking regulators recently conducted of the 19 major U.S. bank holding companies also found that the bulk of the $600 billion of potential additional losses revealed under the more adverse scenario related to loans and other receivables carried on a historical cost basis such as that used in the 1980s and not to items carried on a mark-to-market or fair value basis. In other words, fair value accounting, which is currently applied to only some financial assets, has done a better job of indicating the true financial condition of those assets than the cost basis.

Addressing another criticism of fair-value accounting, Herz admitted that reporting fair values can have procyclical effects on behavior. But he contends that “timely recognition of problems at financial institutions can have countercyclical effects through lessening the impact of financial downturns by providing an early warning of developing problems.”

This year both FASB and the IASB, under pressure from political influences, have struggled to agree on changes to accounting for financial instruments, which involves the fair value applications that have been most widely criticized. Herz provided assurances that FASB and the IASB would continue to work together on these issues, while acknowledging that the two boards have recently had differences in approach and timing. “Next year, once we have received comments and other input on our proposal, we will redeliberate at public board meetings all the key issues identified including discussing them with the IASB and making changes as appropriate,” he said. “Only after having completed this very extensive and thorough public due process will we issue a final standard carefully considering effective dates and transition.”

Original Journal of Accountancy article by Matthew G. Lamoreaux

Tuesday, December 8, 2009

Top Ten U.S.Non-IFRS Accounting Issues and Articles from 2009

The AICPA has an interesting daily email list providing interesting articles from various sources. Below is their summary of the top non-IFRS issues and articles of 2009. Where they use "we" below, they are referrng to CPAs or the AICPA.

This past year brought historical changes and challenges for everyone, CPAs included. Much has been written about the worldwide financial collapse and the hard road to economic stability. In looking back, what strikes me is how CPAs in all work environments held fast to our values of integrity, objectivity and competence despite great adversity. The AICPA joined forces with CPAs throughout the nation to educate Americans on
financial literacy and fiscal accountability, helping to move our country forward.

In protecting the interests of the public and investors, as well as those of the dedicated members of our profession, we spoke out on a range of issues and achieved success for our positions. For instance, pending congressional legislation to create a
Consumer Financial Protection Agency would provide CPAs with a specific exclusion for the advice and counsel they offer to individuals and businesses. The AICPA, along with state CPA societies, wrote letters requesting a delay in enforcement of the Federal Trade Commission's "Red Flags" rule, which was granted -- twice. Last month, the AICPA filed a lawsuit challenging the FTC's application of the rule to CPAs. In support of the Financial Accounting Standards Board's independence, we worked with a House committee to revise an amendment that would have moved accounting standards oversight authority from the Securities and Exchange Commission to a new proposed government agency. Another example is a letter we sent to a Senate committee expressing our opposition to expansion of aiding and abetting liability to third parties in securities fraud claims.

At the same time, we maintained focus on the resources and issues needed to keep CPAs up to date and technically prepared to serve their clients, employers and communities. Major advances were made in pressing areas, from
private company financial reporting and globalization of business and the CPA profession, to sustainability and filling the CPA pipeline for the future. We also won mobility for CPAs, extending interstate practice privileges to a total of 45 states in a collaborative effort with state CPA societies, state boards of accountancy and the National Association of State Boards of Accountancy.

Top 10 news stories clicked by the AICPA's SmartBrief readers in the past year.
Madoff critic: Fraud case "gift-wrapped and delivered" to SEC (2/4)
CPAs get pre-filing-season update on tax laws governing individuals (1/2009)
Does personal goodwill still exist? (4/2009)
Tax aspects of debt modification and discharge (4/2009)
Stimulus bill contains several tax breaks for individuals (2/15)
New tax laws increase 401(k) contribution limits (1/6)
Senate reaches deal on tax credit for home buyers (10/28)
How to calculate gambling gains and losses for tax purposes (2/2009)
Obama's tax proposal draws fire from legislators, business (5/5)
Analysis: Letting estate tax lapse will cause problems

AICPA SEC Conference: No Deadline for IFRS Adoption Yet

Those waiting for clarity from the SEC regarding its road map for adopting International Financial Reporting Standards in the U.S. are still waiting following a speech by the agency’s chief accountant Monday.

In an October
speech, Chief Accountant James Kroeker said the Commission would provide greater clarity on the future of its proposed road map by Dec. 21. In his speech Monday at an AICPA conference in Washington, he gave few additional details, but added, “You can expect to hear more from us in the short term.”

However, during a question and answer session, Kroeker addressed issuers’ concerns over whether they should invest in making changes to their systems. “It’s something that I think you can all expect we’re taking very seriously,” said Kroeker. “If, for example, there was a determination about a date, I don’t think you’re going to wake up in the morning and realize that date means you suddenly have to convert tomorrow to IFRS.”

Kroeker emphasized that the effect on investors would take precedence over other concerns in the SEC’s decision process. “I believe the fundamental focus of our evaluation of implementing a single set of high quality standards must be on the impact to investors,” Kroeker said. “I believe that implementing a set of global accounting standards for U.S. issuers can and must be done only in a manner that is beneficial to U.S. capital markets and consistent with the SEC’s mission of protecting investors.”

While acknowledging that there was no clear consensus on how to conduct the transition, Kroeker highlighted “widespread and strong support” from investors and issuers for U.S. publicly-held companies to migrate to a single set of global accounting standards.

He went on to outline SEC considerations that had similarities to milestones laid out in the SEC’s proposed
road map including:
  • Carefully and fully assess U.S. investors’ understanding of and perspectives on IFRS;
  • The development and application of IFRS, particularly for its use as a single set of standards within the U.S. capital markets;
  • The impact on the U.S. regulatory environment;
  • Preparer considerations including changes to accounting systems, changes to contractual agreements, corporate governance considerations and litigation contingencies;
  • Human capital readiness; and
  • The role of the FASB in achieving the goal of a single set of global standards.

He emphasized the fundamental nature of changes currently being made to both IASB and U.S. GAAP under the boards’ Memorandum of Understanding (MoU) which identifies major projects due to be completed jointly by June 2011. “If revenue recognition is going to be changing and the platform in the U.S. and the platform under IFRS is changing, I don’t know how an entity would go about putting a system in place to adopt IFRS.”

But he seemed to indicate that the Commission does not plan to wait until after FASB and IASB complete their MoU projects before providing more clarity on its intentions. “That doesn’t mean people don’t need or want a greater level of clarity; I said earlier you can expect to hear more from us in the short term.”

But Kroeker said that regardless of future action by the SEC he believes it is important for “FASB to continue to work closely with the IASB to raise the quality of financial reporting standards in the U.S. and around the globe.”

Original article by Matthew G. Lamoreaux, Journal of Accountancy

Top Ten IFRS Stories from 2009

The AICPA has an informative IFRS mailing list. Listed below is a summary of the year’s most clicked IFRS articles on their site.

It has been an interesting year for International Financial Reporting Standards. After a flurry of activity in 2007 and 2008, the first eight months of 2009 were fairly quiet. Other than stakeholders commenting on the
proposed IFRS road map released in November 2008, there was no regulatory action. Then, in mid-September 2009, the Securities and Exchange Commission's chairwoman and chief accountant began to make public statements that would reignite the IFRS discussion. Most importantly, they said more information on IFRS for public companies would be provided by winter, which is right around the corner.

SEC's draft Five-Year Strategic Plan released in early October included support for a single set of high-quality global accounting standards and promotion of ongoing convergence initiatives between the U.S. Financial Accounting Standards Board and the International Accounting Standards Board. Moreover, in late October, the FASB and the IASB reaffirmed their commitment to improve both U.S. GAAP and IFRS and to intensify their efforts to complete the major projects described in their 2006 memorandum of understanding, as updated in 2008, by June 2011.

The AICPA is on record as supporting one set of high-quality global accounting standards for public companies, and we are working to ensure a smooth transition should the SEC decide to adopt IFRS.

Regarding private companies, in July the IASB released
IFRS for Small and Medium-sized Entities (IFRS for SMEs). The AICPA welcomed the introduction of the new standard, which gives private companies an additional accounting and financial reporting option.

Now, we eagerly await the SEC's next move for public companies. Private companies already have the option to use IFRS or IFRS for SMEs because of the AICPA governing Council's action in May 2008 to recognize the IASB as an international accounting standard setter.

Members can stay current on developments and access many helpful resources from the AICPA
IFRS resources Web site.

Top 10 news stories identified by the AICPA SmartBrief readers in the past year.
IASB publishes accounting standard for SMEs (7/9)
G-20 calls for single set of accounting standards by June 2011 (9/27)
Survey: Execs say IFRS will cost U.S. firms more than Europeans spent (3/30)
Schapiro discusses IFRS with IASB's Tweedie (2/12)
Accounting-rule changes would affect equipment leasing (8/14)
IFRS conversion to affect most aspects of operations (9/2009)
FASB, IASB will work more intensely to reach common set of standards (10/29)
CPA Exam to get makeover, include IFRS questions (9/30)
Herz: Full convergence shouldn't delay U.S. adoption of IFRS (4/30)
How to launch a successful IFRS conversion (4/2009)

Thursday, December 3, 2009

IFRS News Roundup

This news roundup is courtesy of the AICPA, and includes a plug for their product at the end.

Monitoring Board lauds convergence talks between IASB, FASBThe Monitoring Board, a key accounting oversight panel, said it is pleased with the direction of the convergence talks between the International Accounting Standards Board and the Financial Accounting Standards Board. "The Monitoring Board is pleased by the responsive approach of the IASB and the FASB to address concerns regarding the potential for the IASB and the FASB to reach different [conclusions] on the major projects," the board said. Accountancy Age (London)

Will convergence be enough?: If efforts to merge international accounting standards are successful, the idea of U.S. companies having to switch standards may become a nonissue, according to this article. The Financial Accounting Standards Board and the International Accounting Standards Board are trying to complete their convergence projects in 2011. CFO Magazine

IASB completes part of new financial-instruments accounting standardThe International Accounting Standards Board has published a new standard on classifying and measuring financial assets. The standard completes the first phase of a three-part project to replace IAS 39, Financial Instruments: Recognition and Measurement. (

IFRS aims to level playing field but causes some concernsThe possible adoption of International Financial Reporting Standards by the U.S. is meant to level the global playing field and make it easier to compare financial statements of companies around the world. However, as this article notes, critics and concerned parties say that the benefits of the global accounting standards would vary considerably among different companies in the U.S. (11/20)

EU postpones introduction of changes to accounting rulesA major overhaul of accounting rules for financial instruments came into force in much of the world recently, but the European Commission decided to postpone adoption of the rules. Analysts said the changes would disproportionately hit some European banks. Other banks in Europe are upset with the decision because they are concerned they will be at a disadvantage compared with their international counterparts. Financial Times (tiered subscription model) (11/13) , (11/13)

SEC's Casey urges continued development of single set of accounting standardsSecurities and Exchange Commission member Kathleen Casey called for continued efforts to converge international accounting standards. The SEC is considering a plan that would have companies use International Financial Reporting Standards. "The commission and the [Financial Accounting Standards Board] would be remiss and fail the needs of investors if we do not continue to support the development of a single set of high-quality global accounting standards," Casey said. Reuters (11/17)

Some companies may use new IASB rules despite delay in BrusselsSome European companies may prepare "proforma" accounts as if new accounting rules were in place even as the EU signals it may delay implementation of the so-called IFRS 9 rules. Four companies said they may use the rules to prepare accounts for internal use before the end of 2009. The new rules from the International Accounting Standards Board address how financial institutions value assets. For IFRS daily updates, training courses, case studies and other resources, visit Financial Times

OCC questions IASB's proposed loan-loss accounting standardJohn Dugan, comptroller of the currency, said a loan-loss accounting standard proposed by the International Accounting Standards Board is "potentially too restrictive." Dugan said accounting standard setters are heading in the right direction, but he raised concern about some of the proposals. "If expected loss is interpreted in a way that constrains it so you don't get to look forward, then we will not have made much progress," Dugan said.

CESR chairman says review of IASB governance is neededEddy Wymeersch, chairman of the Committee of European Securities Regulators, told the European Parliament's economic and monetary affairs committee that an assessment of the governance of the International Accounting Standards Board is needed. Wymeersch raised questions about the accountability of the accounting standards setter. The New York Times/Reuters

HSBC's CFO urges Europe to quickly adopt IFRS 9Douglas Flint, chief financial officer at HSBC, says he wants to see Europe adopt the International Accounting Standards Board's new rule on fair-value accounting, known as IFRS 9. Flint says he believes critics pressured the IASB for political purposes. "Many of the objectors to IFRS 9 sought to take the IASB to a position they knew it could never support, because their agenda was to create conflict with the IASB as part of a larger political agenda," Flint said. Accountancy Age (London)

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