[UPDATE]: Allow me to update this piece with this delightful piece of news re the commercial paper market. AT&T can probably survive this for a little while. Plenty of other companies can’t.
One of the items in the proposed bailout that a number of Republicans seem to be insisting on is either a suspension or outright end to mandatory mark to market accounting rules. It is supposed by many people that this will somehow aid the unfreezing of the credit markets and/or provide liquidity to the market. Count me among those who are not so sanguine about the long-term prospects of suspending MTM; in fact, I suspect that it may make the situation worse.
In the very, very short term, the suspension of MTM may help certain companies who have built in balance sheet triggers in contracts, credit agreements, or corporate charters and/or bylaws to avoid immediate catastrophic consequences. But as a systemic matter, the suspension of MTM would seem to inject more uncertainty into the market, which is frankly the very last thing the market needs right during the middle of a crisis of confidence.
To review, the accounting fiascos of 1999-2002 that brought us mandatory MTM accounting taught us that traditional accounting methods make it easier for a company – through “aggressive” accounting – to appear solvent for much longer than the company actually is solvent. Everyone in the lending world remembers this. To further review, a large part of the genesis of the current crisis is a widespread fear that certain assets are toxic, and that it’s impossible to identify the toxic assets from the good ones. So… I guess we’re supposed to assume that allowing a change of accounting rules which leads the credit markets to believe that companies might be (but no way to tell for sure) faking solvency is a good thing?
If we suspend MTM in the current climate, what exactly is supposed to happen? Will companies hire accountants to come in and hastily rewrite their accounting books? If they do, will any lender actually extend them credit without forcing them to crack open the old MTM books instead? And if they can’t force that, will they lend at all? Like I said, the market will go from widespread uncertainty about certain classes assets to having widespread uncertainty about every company, especially in these uncertain times. I fear that this may make the credit markets freeze even tighter than they are, even if we inject a bunch of liquidity into the system.
I suppose there’s a reason why this analysis is completely wrong – and frankly, I hope it’s completely wrong. But I’m just not seeing it at this point.
Steve Maley
Neil Stevens
Daniel Horowitz
market to market
wsjreader (Diary) Thursday, October 2nd at 9:03AM EST (link)This is another example of stupid politicians meddling into intricate accounting rules to try to solve the ‘problem’.
It’s laughable that Wall Street fat cats can successfully persuade those Washington politicians that an accounting rule based on reality has actually caused this mess.
Market-to-market is a sound concept. The argument that there will be some ‘intrinsic value’ in the future for those toxic assets is simply a myth. We don’t know what the ‘intrinsic value’ is, and nobody knows. The idea that you hold those assets long enough, they will automatically go back to their ‘intrinsic value’ is simply idiotic.
I'm no expert...
Crowe (Diary) Thursday, October 2nd at 9:10AM EST (link)…and I’m learning how to use terms I’ve never used before, but…
Seems to me that certainty about present prices for long-term assets (if that’s an apt term for real estate and other assets that the holder intends to keep long-term) doesn’t matter nearly as much as the long-term value of such assets when assessing a firm’s financial standing and strength. I certainly see some value, especially these days when once-strong companies are forced to sell off such assets right now, in noting the MTM values of long-term assets, but that seems to be the opposite problem: assuming these companies are not strong. Such assumptions would seem to feed, rather than fight, the crisis in confidence that underlies much of the trouble.
Suspending MTM rules — which were not part of the market until recently — likely will prevent much of that self-fulfilling pessimistic prognostication.
I also may be totally off-base (I’m treading in waters I’ve barely dipped a toe into before) but that’s part of hte understanding I’m coming to on all this.
“We sleep soundly in our beds only because
rough men stand ready in the night to visit violence upon those who would do us harmDear Leader Obama gives us leave to do so.”IANAA, but
cwilson (Diary) Thursday, October 2nd at 9:10AM EST (link)it seems that the MTM “problem” is as follows: you own a bunch of assets, and I own some similar assets. You have (for some unrelated reason) gotten into a financial jam — maybe you are more heavily invested in MBS than I am — and your creditors have forced a “margin call” on you.
So, you have to have a fire sale to raise capital by tomorrow morning. You obviously are going to sell your least-performing assets — but, because you MUST sell, and MUST raise money NOW, you are a classic distressed seller. You get a very low price on those assets.
Me, I’m in no immediate trouble. I have no need to sell anything or raise any capital. Sure, I’ve got some MBS in my portfolio, but not enough to put me in distress under normal circumstances (e.g. I am NOT a distressed seller and don’t have to take firesale prices).
But under MTM rules, just because YOU had to hold a fire sale, I have to assume that my MBS assets are ALSO only worth pennies on the dollar — even though I don’t need to sell them overnight.
And that’s the rub: BECAUSE I had to mark down my assets to your distressed price, now MY creditors are looking at my balance sheet and saying: you have to raise capital…and so the contagion spreads. I’m now in trouble, but through no fault of my own. I have to hold a firesale — but only because MTM forced me to devalue my assets based on YOUR firesale!
If ye love wealth better than liberty, the tranquility of servitude than the animated contest of freedom — go home from us in peace. We ask not your counsels or arms. Crouch down and lick the hands which feed you. May your chains sit lightly upon you, and may posterity forget that you were our countrymen! –Samuel Adams
MTM not just on the toxic assets... right?
Crowe (Diary) Thursday, October 2nd at 9:13AM EST (link)I was under the impression that the MTM rules suspension wouldn’t apply only to the toxic assets (which, of course you’re right, have no ‘known value’ to fall to, so conventional value assessments are impossible) but would apply to all assets, including those that do have discernible long-term values… And establishing the value of more stable, non-toxic assets according to less-volatile, more realistic long-term values would seem to help tremendously…
Again, am I completely missing something?
“We sleep soundly in our beds only because
rough men stand ready in the night to visit violence upon those who would do us harmDear Leader Obama gives us leave to do so.”My gut is that Crowe has it right, Leon
Dave_in_Fla (Diary) Thursday, October 2nd at 9:22AM EST (link)The suspension is only useful for allowing banks to fudge their balance sheet and modify their asset to loan ratios. Use by anyone other than a bank doesn’t seem to be all that useful in this mess.
But then I am learning a lot of things this week too, so maybe someone with more expertise can educate us.
“If they were merely incompetent, then at least SOME of their actions would have been to the benefit of the country.” – Joe McCarthy
Re: IANAA, but
sorrodos Thursday, October 2nd at 9:25AM EST (link)I’m no accoutant either, but my wife is. She’s an auditor with her CPA at a Big 4 firm.
I haven’t seen her get too fired up about anything in this bailout talk except the push to suspend MTM rules. She thinks its an absolutely awful idea.
My initial reaction to talk of doing this was similar to those who are pushing to suspend the rules, because I can see that sometimes certain assets may have a value in the long term even if they are in bad shape at a specific time before then.
However, I can’t think of what the alternative is. How exactly is it supposed to work?
It just seems to be that suspending the rules will be misleading to investors and inflate values of certain companies/sectors/etc. And weren’t artificially inflated housing prices one of the big reasons we’re having these problems right now?
Full disclaimer: this is my first comment here… I’m a liberal lurker
market
wsjreader (Diary) Thursday, October 2nd at 9:30AM EST (link)You’re right. Market to market applies to all securities assets held by the firm. The details are far more complicated than the headline slogans. If my memory is correct, there are three types of valuation methods you can apply to. For example, some assets you can classify them as held-to-maturity, and you don’t need to apply market-to-market on a quarterly basis… So basically the current accounting rules have covered lots of ground. Those rules are really not all that rigid which Wall Street fat cats and Washington politicians want you to believe.
What the Wall Street fat cats want is to persuade the politicians that those toxic assets will have far better value if they’re just being held long enough. They will sell those toxic assets at a good price to the taxpayers under this grand bailout plan, and then scoop them up from the treasury at a huge discount in a few years when nobody wants to buy them. It is absolutely crazy.
MTM was a powerful reform
hunter (Diary) Thursday, October 2nd at 9:35AM EST (link)We withdraw it at our peril.
The first rule of medicine is ‘do no harm’.
I think the more Congress screws around with this, the less likely the first rule will be followed.
hunter
I posted this comment at CFO.com in May 2008
Charles Smith (Diary) Thursday, October 2nd at 9:37AM EST (link)We’ve been through this before.
I’ve a couple of references that put forth the statement that:
“Historical Cost Accounting
Historical accounting replaced fair value accounting during the 1930s post Great Depression period. This was replaced since the values had been overstated by certain companies. The principles of historical cost accounting came into being post Wall Street Crash which took place in 1929 along with the assumption of stable currency. ” see: Inflation Accounting
Also Risk Management
Note slide titled “Background II” on page 5 of the above referenced PDF.
I’m having trouble finding the source information from which these observations were gathered. I welcome any help that can be provided.
“No people will tamely surrender their Liberties, nor can
any be easily subdued, when knowledge is diffusd and Virtue is
preservd. On the Contrary, when People are universally ignorant,
and debauchd in their Manners, they will sink under their own
weight without the Aid of foreign Invaders.”
– Samuel Adams (letter to James Warren, 4 November 1775)
I posted this comment at CFO.com in May 2008
Charles Smith (Diary) Thursday, October 2nd at 9:38AM EST (link)We’ve been through this before.
I’ve a couple of references that put forth the statement that:
“Historical Cost Accounting
Historical accounting replaced fair value accounting during the 1930s post Great Depression period. This was replaced since the values had been overstated by certain companies. The principles of historical cost accounting came into being post Wall Street Crash which took place in 1929 along with the assumption of stable currency. ” see: Inflation Accounting
Also Risk Management
Note slide titled “Background II” on page 5 of the above referenced PDF.
I’m having trouble finding the source information from which these observations were gathered. I welcome any help that can be provided.
“No people will tamely surrender their Liberties, nor can
any be easily subdued, when knowledge is diffusd and Virtue is
preservd. On the Contrary, when People are universally ignorant,
and debauchd in their Manners, they will sink under their own
weight without the Aid of foreign Invaders.”
– Samuel Adams (letter to James Warren, 4 November 1775)
My quick response
MSU_Charles Thursday, October 2nd at 9:39AM EST (link)I don’t have but a minute. I have to teach in 4 minutes, so if this does not make sense I will clarify later. MTM is probably the accelerant to this crisis. The problem is, once again, Washington’s knee jerk reaction to Enron, Worldcom. etc in passing Sarbanes Oxley. MTM is part of it. The problem is specifically FAS 157 & 159 that was intended to clarify what MTM actually meant. However, it did not. In an effort to not face the penalties of incorrectly reporting assets CFOs & accountants have been using too conservative of estimates in valueing assets. Mainly, because of the lack of clarity. However, this issue is deeper and I will return to the subject after class. See the link below and it explains fairly well what is going on. I will end with this question, “how do you place a market value on an asset that is illiquid (trades infrequently)?”
http://www.forbes.com/home/2008/09/29/mark-to-market-oped-cxng0929gingrich.html
auditors
wsjreader (Diary) Thursday, October 2nd at 9:42AM EST (link)You’re absolutely right, all CAs and auditors are vehemently against this new ruling. It’s crazy.
In that case...
Crowe (Diary) Thursday, October 2nd at 9:43AM EST (link)What’s the solution?
Just to toss this out there, if the Treasury buys these toxic assets at time x for, say, $10 each, and sells them at time y for $20 each (even though they were at one point years before the present crisis worth $50 each and, at time y, could easily be sold at $40 each), the Treasury has still doubled its money. Granted, it could have quadrupled its money, but doubling ain’t bad…
Yes, the Wall Street fat cats will have made out pretty well also when they sell them for $40 or more, but is that soooooo bad if the action taken at time x (that’s today) stabilizes things and lets the market right itself?
Again, just tossing that out there so that I might get a grasp on things; I don’t necessarily think it’s the right way or the best way.
“We sleep soundly in our beds only because
rough men stand ready in the night to visit violence upon those who would do us harmDear Leader Obama gives us leave to do so.”Without *any* specific expertise in accounting
MikeO Thursday, October 2nd at 9:43AM EST (link)My take on MTM suspension is this: Suspending MTM gives better transparency because it forces a deeper look into the assets in question. With MTM, there is absolutely no point in trying to determine the real value of the MBS or whatever “toxic” asset you own because the only number you are allowed to put on the scoreboard is the last sale made regardless of circumstances. So why bother when the only way out is to say, “don’t know, ergo zero.”
We have similar things in the IT field—particularly when it comes to security plans. Every new exploit or exposure that comes down the pike results in a new rule or set of rules for determining the risk of operating a system. After writing your n-thousandth mitigation/exception plan, you get to the point where you throw-up your hands, you find something else to do, and you get replaced by somebody who is willing to say, “Nope. Can’t do it. The rules make it impossible.”
SEC / FASB already loosened the noose
Guerc Thursday, October 2nd at 9:47AM EST (link)You guys are missing the point. It’s already been done.
SEC and FASB put out interpretive guidance yesterday. They gave more leeway for managements to use “Mark-to-Model” rather than “Mark-to-Market”, when there is no active market for those assets. This will releive a ton of pressure on banks.
The stupid thing about MTM accounting is it forced banks to write down their assets to the lowest fire-sale price for similar assets, even if they didn’t plan or need to sell.
This was be like forcing homeowners to value their net worth based on the foreclosed value of a house a mile away. If the net worth dropped enough, the homeowner would have credit and debit cards shut off, and forced to immediately repay their car loan.
Guerc, CPA
wrong
wsjreader (Diary) Thursday, October 2nd at 9:51AM EST (link)You’re wrong. Banks won’t sell those toxic assets at 10 cents on a dollar to the treasury. What’s the point for them to do so? They can liquidate those assets at a better price. It will not boost their capital in a meaningful way.
The better analogy is that they will sell those assets at 50 cents on a dollar to the treasury, and then expect to purchase them back at 20 cents on a dollar in a few years.
Then the problem is Sarbanes Oxley
Crowe (Diary) Thursday, October 2nd at 9:54AM EST (link)I did see that SEC memo about MTM suspensions… but with Sarbanes Oxley still in place, won’t the desired benefits of MTM suspension be minimal as accountants are overly careful about establishing values lest they get in serious trouble for accidentally overvaluing assets? (I mean that sincerely — honestly, in good faith, valuing things at what turns out later to be overvalue)
“We sleep soundly in our beds only because
rough men stand ready in the night to visit violence upon those who would do us harmDear Leader Obama gives us leave to do so.”So even though they're spending $.7T, it might not work?
birdmojo (Diary) Thursday, October 2nd at 9:59AM EST (link)Something must be done.
This is something.
What do you mean it’s making things worse?
Man is free at the moment he wishes to be. –Voltaire
Ethics
MikeO Thursday, October 2nd at 9:59AM EST (link)Early in my career, the General Counsel for the large organization that employed me explained that his Chief Ethics Officer hat implied much more than keeping the organization well within the boundaries. That, he said, was a job that any non-illiterate jackass could do. His job, as he saw it, was to define what could be done at the edges of the law.
Post-Enron and under SOX, most of business has been operating under the tyranny of non-illiterate jackasses.
Ok, we're getting somewhere...
Crowe (Diary) Thursday, October 2nd at 10:00AM EST (link)Of course the banks don’t have incentive to sell the assets at $.10 only to buy them back at higher.
But by the same token, wouldn’t the Treasury have just as little incentive to sell them back at less than they bought them for? What of all the talk that these assets would be held by the Treasury only until things got righted and their worth was buoyed by the overall rising market and were then worth more than purchased for, but less than otherwise would be in a market that hadn’t suffered a near-death experience…
In short, what of all the talk that the Treasury will actually make money out of all this?
“We sleep soundly in our beds only because
rough men stand ready in the night to visit violence upon those who would do us harmDear Leader Obama gives us leave to do so.”assumption
wsjreader (Diary) Thursday, October 2nd at 10:18AM EST (link)You’re right on the money. The key is the huge assumption that tho value of those assets will EVENTUALLY bounce back with the overall rising market.
Japan has experienced 10 years+ of deflation after the house bubble burst. There is absolutely no guarantee the value of those assets will be back especially considering many of those paper assets(MBS etc) are highly leveraged stuff, and many were based on fancy computer models. The link between those paper assets and the underlying physical mortgages were skewed to an alarming degree.
got it, thanks (nt)
Crowe (Diary) Thursday, October 2nd at 10:23AM EST (link)n/t
“We sleep soundly in our beds only because
rough men stand ready in the night to visit violence upon those who would do us harmDear Leader Obama gives us leave to do so.”5+
asleep06 (Diary) Thursday, October 2nd at 10:30AM EST (link)nt
Small is beautiful.
Oh no!
asleep06 (Diary) Thursday, October 2nd at 10:35AM EST (link)“Your ability to plan for investment is obviously affected. You kind of don’t know what your cost of capital six months from now is going to be,” he said. “We’ll just be very guarded, cautious in terms of where we invest, very guarded and cautious in terms of hiring and capital spending. We’ll see where this situation goes.”
Wow, you mean these times are forcing companies to be… financially prudent? That in an economic downturn you might have to… tighten your belt?
You’ll forgive me if I don’t cry for AT&T’s troubles since they’ve been reaping easy credit from Lehman Bros for years and not saving for a downturn.
Man, I made a bad investment the other day. Is someone going to bail me out with money that doesn’t belong to him or me?
Small is beautiful.
I've got a receipt for pets.com stock.
birdmojo (Diary) Thursday, October 2nd at 10:58AM EST (link)I don’t, actually, but I heard (on NPR!) while driving into work one of those government types was fretting about the prices of housing going down.
Here’s a quick tutorial:
Inflation is not the same as growth.
Prices going up is not the same as value increasing.
Supply and Demand work together in weird ways. If you have a lot of supply and not a lot of demand, prices will be lower.
If you want prices to go up, you either have to restrict supply or increase demand.
It should not be the job of the government to fret about the prices of commodities going down. Now, of course, if they go up too high, the government probably ought to support, say, offshore drilling.
But that’s neither here nor there.
Man is free at the moment he wishes to be. –Voltaire
My quick response
MSU_Charles Thursday, October 2nd at 11:05AM EST (link)I don’t have but a minute. I have to teach in 4 minutes, so if this does not make sense I will clarify later. MTM is probably the accelerant to this crisis. The problem is, once again, Washington’s knee jerk reaction to Enron, Worldcom. etc in passing Sarbanes Oxley. MTM is part of it. The problem is specifically FAS 157 & 159 that was intended to clarify what MTM actually meant. However, it did not. In an effort to not face the penalties of incorrectly reporting assets CFOs & accountants have been using too conservative of estimates in valueing assets. Mainly, because of the lack of clarity. However, this issue is deeper and I will return to the subject after class. See the link below and it explains fairly well what is going on. I will end with this question, “how do you place a market value on an asset that is illiquid (trades infrequently)?”
http://www.forbes.com/home/2008/09/29/mark-to-market-oped-cxng0929gingrich.html
bird, was this for me?
asleep06 (Diary) Thursday, October 2nd at 11:30AM EST (link)Anyway, yeah it used to be common sense that if you didn’t actually improve your house (e.g. upgrading the central air or finishing the basement), price increases aren’t a reflection of the real value of the house but just inflation.
Now people actually believe that value just appears over time with no effort or actual improvement!
Of course, there are other factors that increase property values, like neighboring property improvements, but generally, most of the price increase is inflation, as you say, rather than actual increase in value.
Small is beautiful.
I long ago
fladem Thursday, October 2nd at 11:39AM EST (link)stopped posting here, for reasons that are probably obvious, BUT
I work for a Big 4 firm as well. The suspension of MTM boggles my mind. A fundemental problem right now is lack of transparency. Repealing MTM actually makes this problem worse.
I now return to my usual lurking here……
Even penecillin wasn't a perfect magic bullet
The_Gadfly (Diary) Thursday, October 2nd at 12:14PM EST (link)It seems to me that MTM has its uses and proper place. Frequently traded types of assets would be one of those places. Infrequently traded assets are not. What’s the MTM of the Mona Lisa? It’s unique, irreplaceable, and not for sale anyway. So that’s a question that doesn’t make much sense. Right now MBSes are sort of the reverse, but that doesn’t mean the same principles apply.
To use a slightly different example, some years ago I was at a grocery store when there was an area wide power outage and they didn’t have backup generators. They weren’t taking checks, and obviously the atms and their credit card processing units were down. They were selling fresh meat for 30% of the face value if you paid them cash. Does that mean the value of all meat everywhere in the US should have been marked down to 30% of face value? That doesn’t make sense, but it is what MTM seems to require. Common sense says, you have to exclude the price of meat at that store when determining the inherent value of steak. The problem is how to do this consistently. I don’t think there is a law or rule that gets us there.
Somehow or another, we need to get back to the point where people like mbecker98, who (based on the posts I’ve seen from him) would have the good sense not to loan me money, instead of the people running places like Citibank, Capital One, and Bank of America, who keep sending me credit card offers based on mythical models of how much I can pay them.
Mark to Market is a Red Herring
enrique Thursday, October 2nd at 12:18PM EST (link)The ruling being blamed on today’s crisis is a herring. As C.B. stated above, it probably accelerates things but is not the root cause of our credit crisis. The fact that we have people leveraged on top of leveraging has made it impossible to assess the value of companies/banks.
It is our system of credit by the Federal Reserve that has led us to this point. You cannot expect to borrow forever and then not ever have to prove your solvency. Eventually the market call comes so those firms overly leveraged will fail. No matter whose fault it is like the Fed’s or Congress or CEOs or shareholders. It was risky and they goofed.
“There are a thousand hacking at the branches of evil to one striking at the root.” Henry David Thoreau
It's not the cause
MikeO Thursday, October 2nd at 12:35PM EST (link)MTM is not the cause of the crisis. MTM likely contributes to the crisis. MTM definitely blocks the market from making any positive movement to resolve the crisis.
So long as holders of toxic assets are required to value these assets at the price of the last distressed sale or risk going to jail, there is not only no incentive to take a closer look, but there is no authority to do so. In other words, valuation is effectively a black box with observed outputs that can only decay toward zero.
More of a gut rumble, really.
birdmojo (Diary) Thursday, October 2nd at 12:45PM EST (link)The tutorial wasn’t for you, it was for the prominent government official who considered house prices going down to be a sign of the economy failing.
Hey! House prices in Zimbabwe? They’ve been going up quite reguarly!
Bread prices too, for that matter.
Man is free at the moment he wishes to be. –Voltaire
You picked the wrong quote
The_Gadfly (Diary) Thursday, October 2nd at 12:47PM EST (link)The point is they’ve been forced to buy volatile credit instead of financially prudent longer term credit. I dislike AT&T as much as the next guy, but their CEO is right: When you don’t know on a daily basis what your costs are going to be, it becomes impossible to plan long term projects. Fear sets in, jobs don’t increase, markets contract, the economy falls. I think they call it a panic. I’m not sure, even though I’m only a handful of years short of the half century mark, I’ve never experienced one. I rather suspect I won’t enjoy the experience, it won’t be good for me, and I suspect the same will be true of many other people as well.
perhaps...
briefsynopsis (Diary) Thursday, October 2nd at 6:42PM EST (link)Like many others in today’s current climate, you seem to have a very cynical outlook on how business is actually transacted. Every company started out at one time with an entrepreneurial dream. My experience is that businesses are run with integrity, the larger the business and the longer it has operated, the greater the chance to instill that ethos.
MTM on a three year rolling average is not that far off as a true indication of product value. A three year rolling average gives both, small mom and pops, and corporate behemoths, the ability to smooth out the peaks and valleys. Thus giving the smaller company the ability to survive aggression by larger corporations and the ability to demonstrate market knowledge, and in doing so, perhaps increasing the likelihood of attracting angel investors or stockholders. (then, and only then, can they become the large liberal corporations that you deem most companies to be.?)
Have you Hugged a “Special Operations Warrior” today?