Fair Value Accounting: Implications For Banks
- The significant fact of fair value measurement is to determine the exchange price for a particular asset or liability, which is being measured in the absence of an actual transaction for the same asset or liability.
- To measure fair value of a firm, it has been determined through various valuation models by taking the consideration of relevant data from their accounts, such as general market conditions, current economic forecasts, the price of similar financial instruments etc.,
- Market value accounting is intended to avoid volatility in the period of gains and losses that are appreciated before recognition of all realized gains or losses in one period.
- The fundamental nature of bank management in this area lies on captivating the long-term decisions about credit quality and concentrating on fostering the customer relationships within the contract period.
- This attempt focuses on the role of mark-to-market concerns in banking, critical aspects in implementing fair value practice and the road ahead.
Abstract: The article focuses on the implications of fair value accounting practices in banking regulations. It throws light at the significance of fair value accounting, its impact on financial instruments, the mark-to-market concerns in banking industry, various critical aspects in executing fair value.
Introduction:
The fair value is playing a vital role in accounting for various financial instruments of different institutions. The principal intention behind fair value measurement is determining the exchange price for a particular asset or liability, which is being measured in the absence of an actual transaction for the same asset or liability. Typically, fair value measures are used to comply with public reporting requirements, companies determine their financial instruments at fair value for various internal procedures such as managing and measuring risks, making trading and investing decisions, calculating compensation and determining how much capital to devote for various lines of business. Both the FASB and the International Accounting Standards Board (IASB) are jointly working on various projects to examine the feasibility of recognition of financial assets and liabilities at fair value in the financial statements.
According to the definition of fair value, it is the price at which a willing buyer/seller agrees to trade. Hence, finding the accurate price is the key objective in the valuation procedure of a “fair value”. The firms can easily find these prices of a particular financial instrument in newspaper, websites and other quotation systems. In general, these prices reveal the last price decrypted to the secondary market. These kind of listed and published prices are unavailable for all kinds of financial instruments. In such cases, there should be a full-fledged assessment to determine fair value. Measuring a fair value of a firm, has been determined through various valuation models by taking into consideration of accounts and some relevant data, such as general market conditions, current economic forecasts, the price of similar financial instruments etc., Normally, the certified market data subsists to reinforce the objective determination of fair value through modeling. Besides this, the firms rely on the judgment only for very composite instruments, where market factors and prices do not exist.
Cost Benefit Analysis:
According to Congressional Committee report, there are two principal benefits of necessary fair value accounting for financial instruments. The primary benefit is, it would moderate the use of accounting-motivated operational structures, which are designed to make use of opportunities for earnings’ management which is created by the current “mixed-attribute” (which includes part of historical cost, part of fair value) accounting model. The secondary benefit is that the fair value accounting for all financial instruments would condense the complication of financial reporting taking place from the “mixed-attributed” model. One of the chief concerns of financial statement is that fair value can be reliably measured in active market conditions.
A cost, to investors of fair value dimension, is that some or more have accepted the financial instruments and may not be estimated with adequate precision to help them in assessing the firm’s financial position and earnings potential adequately. This consistency cost is compounded by the setback in the absence of active market conditions for a particular financial instrument. Management should measure its fair value, which can be subjected to discretion or manipulation. Evaluating the overheads and remunerations of fair value accounting for financial reporting to investors is causing difficulty for the other financial statement users in certain reporting regimes. Within the same light, fair value accounting is playing a vital role in assessing banks in the way of supervisory issues and becoming mandatory for its regulatory capital.
Fair Value Practices in Assessing Banks:
In the year 2000, the Financial Instruments Joint Working Group (JWG) of Standard Setters has issued a draft for financial instruments. It reviews and evaluates the extensive usage of fair value accounting as a foundation for the valuation of all financial instruments in a bank’s balance sheet. This was in association with the long-term strategies of the International Accounting Standards Committee (IASC) {recently it was replaced by the International Accounting Standards Board (IASB)} to establish a comprehensive framework of fair value accounting for the recognition and measurement of financial instruments. The European Central Bank (ECB) has proposed an important dimension in the application of fair value accounting to the banking sector. It mainly sheds on the significant aspects, which are associated with the application of fair value accounting and its regime to the banking sector and presents a possible way forward.
The current accounting rules for banks have been differentiated between financial instruments for trading purposes (in the trading book) and maturity (in the banking book). The financial instruments which are detained in the trading book are valued at market prices. Thus, the accounting rules for the trading book instruments contains all kinds of market risks such as price, interest rate, foreign exchange and liquidity risks of an account. In contrast, banking book instruments are approved in the balance sheet at the minimal historical cost and market value. While the loss occurs in the banking book, instrument, it is transferred to the profit and/or loss account and the unexpected gains are not considered. Hence, the gain will be a hidden reserve in the balance sheet. Thus, the accounting rules for the banking book instrument will not involve any sort of market risks into account.
The assets and the liabilities are carried in the balance sheet at market value, if they are available, or at fair value calculated as an approximation of the market value by using a present value model for discounting the expected future cash flow[1]. For banks, this would entail that trading and banking books would receive equal accounting implementation strategies, through all changes in value would be recognized in the balance sheet as well as in the profit and loss account. The anticipated revaluation applies irrespective of whether profit or loss has been realized or remains unrealized because all instruments either marked to market or fair value is measured. As a consequence, the hidden reserves may disappear under the current accounting rules. While calculating the value of financial instruments in both trading and banking books, market risks would be taken into consideration.
The Mark-to-Market Concerns in the Banking Industry:
Of late, the contemporary issue in the banking industry, which is supported by the Securities and Exchange Commission (SEC), is focusing on the new accounting regulations to facilitate change in the accounting valuation of securities for financial institutions. Banks are in need of market values for investment securities portfolios. Unfortunately, this practice was neglected due to regulators’ extreme concerns of negative effect from mark-to-market concern on banks financial performance, decision making process and investment decisions. As a result, Market Value Accounting has been introduced by various financial statement users as well as accounting professionals in the period of 1970’s and 1980’s.
One of the strongest rationale facts for market value accounting is that “GAAP relies on the historical cost (book value) of transactions. As a result, the structure of economic reality is often misleading”. The believers of market value accounting trust that volatility is one of the most important reasons to adopt market value accounting. With the help of investments in securities and their performance in the market are reflecting on financial stability of various financial institutions. Market value accounting is intended to avoid volatility in the period of gains and losses that are appreciated before recognition of all realized gains or losses in one period. Some other practitioners opines that even if market value accounting is not always the best measure of fair value in the absence of a liquid market, it would not reflect on the most relevant value over historical cost.
The most successful financial institutions will be those who keep money-making securities and get rid of the unprofitable securities from current portfolios as soon as possible. In addition, it would be cautious to take random losses to improve future portfolio performance by selling unprofitable securities. Market value accounting provides a more pragmatic picture, worth and enhances the long-term investments of that particular financial institution. It can be used as a tool to monitor and improve the performance of current portfolio management of a particular financial institution.
Critical Aspects:
According to the supporters of these accounting standards, fair value accounting may represent in the conceptual approach. This can be an alternative for the financial reporting to determine the financial performance by avoiding various problems which are allied with the existing historical cost accounting. One of its most important objectives would be to enhance the degree of transparency of financial statements. On the other hand, this opinion continues as a speculative, due to the absence of homogeneity and comparability in fair value accounting methodologies. Moreover, the existing procedure of a full Fair Value Accounting regime to the banking sector arises few problems and concerns. The methodology of fair value accounting may be apt for the trading book of banks (which refers to transactions, i.e., buying or selling) or profitable securities and related instruments with the objective of making a profit from short-term price variations. The use of fair value for these transactions is reliable with the accessibility of market prices and the short-term horizon. Still, the performance of fair value accounting to the banking book of banks (to non-negotiable instruments) appears to be unsuitable for the following three main reasons.
1. The Issue of Relevance: The principles of fair value accounting do not reflect properly on the way in which banks manage their core business (especially for granting loans). The fundamental nature of bank management in this area lies in captivating long-term decisions about credit quality and concentrating on fostering the customer relationships within the contract period. It is less concerned about short-term dissimilarities corresponding to the foundation for the usage of fair value accounting principles. Hence, there is an opportunity to introduce these fair value accounting principles and practices for the banking book may create incentives to alter their core businesses of banks. This would be the case, if banks decided to trim down their disclosure to increase volatility of income by shortening the average maturity of loans. Further more, it is useful to accomplish and recourse the goals, hedging techniques and the implementation of variable interest rates. The decision behind diminishing the standard maturity of loans would depend on various aspects such as nature of customer’s demand and the specific cost structure of individual banks.
2. The Issue of Feasibility:
Since the accounting practices personify elements such as, The (International Accounting Standard) IAS 39 “Financial Instruments: Recognition and Measurement”, which is effective for accounting periods since January 2001, has already unmitigated for the use of fair value in relation to the banking book by imposing the fair value revaluation of assets available for sale. There are serious doubts that a satisfactory fair value can be measured for bank loans, which are non-negotiable instruments, accurately. Thus, the purpose of fair value accounting to bank loans would arise numerous uncertainties which are hindering and working against the transparency and comparability of financial statements. The uncertainties are rising with regard to the purpose of fair value accounting in the liability side of banks’ balance sheet. To measure the fair value of a debt instrument, which is issued by banks, involves that, if the rating of a bank declines, ultimately the value of equity will increase. In an end, this will be a counter-intuitive and can be deceptive for shareholders as well creditors.
3. The Issue of Prudence:
The efficiency of fair value accounting in the banking book would require potential profits and losses. This goes against the ethics of prudence, according to, which losses stemming from the banking book and should be recognized as soon as they popular, even if only possible, where profits should be recognized only if they are actually realized. Therefore, there is a possibility that the application of fair value accounting to the banking book might encourage the banks to accept an imprudent behaviour. This is a fundamental aspect from the banking supervisory function.
Conclusion:
From the times of yore, risk management and reporting issues, which are associated with bank valuations of complex or illiquid financial instruments; the implementation of regulatory capital obligations and bank supervision have received considerable attention. With the relevance of fair value accounting to a wider choice of financial instruments, together with experiences from the current market turmoil, emphasizes the critical importance of vigorous risk management and control processes around the measurement of fair values and their consistency.
These accounting principles seek to support a strong governance procedure of valuations; such as articulation and communication of valuation, uncertainty within a bank and external stakeholder, reliable inputs and diverse information sources. It also seeks for allocation of sufficient banking and supervisory resources, consistency in valuation practices for risk management and reporting purposes, etc., The bank regulators should consider fair value accounting while measuring the value of bank regulatory capital and making regulatory decisions. In the arena of financial reporting, IASB and FASB have introduced several disclosures, measurements and recognition standards for financial instruments with respect to fair value accounting. The bank regulators should let the managers reveal the concealed information while measuring the fair value; need to consider the effectiveness to investors & creditors. Cross-country institutional differences are playing a significant role in shaping the use of mark-to-market accounting for financial reporting and bank regulation.
The foremost improvement should involve where fair value accounting would not be accepted as an accounting standard for the book of banks, regulatory authorities may use it as a supplementary instrument of individual credit institution. The secondary step-up should entail the acceptance by banks (so-called dynamic provisioning). This requires recognition of proportion of the loan portfolio, which can be deteriorated in future and can measure specific statistical analysis. It would also engage with various disclosures by banks and results interest rate sensitivity of the banking book. The move towards new accounting standards should allow two criticisms associated with their principles need to overcome, particularly with respect to the potential credit losses, which remain hidden until signs of deterioration are evident and market participants have inadequate information about the interest rate risk profile of banks.
Reference:
- “Financial Instruments Fair Value Accounting for (not against) the Banking Industry”, http://papers.ssrn.com/sol3/papers.cfm?abstract_id=430260 by Günther Gebhardt, Rolf Reichardt and Carsten Wittenbrink
- “Fair Value Accounting in the Banking Sector”, www.ecb.int/pub/pdf/other/notefairvalueacc011108en.pdf, A Draft from European Central Bank.
- “Supervisory Guidance for Assessing Banks’ Financial Instrument Fair Value Practices”, http://www.bis.org/publ/bcbs145.pdf, A Consultative Document from The Bank for International Settlements (BIS).
- “Fair Value Accounting for Financial Instruments: Some Implications for Bank Regulation”, www.bis.org/publ/work209.pdf by Wayne R Landsman.
- “The Mark-to-market Concerns in the Banking Industry”, http://findarticles.com/p/articles/mi_qa3682/is_199501/ai_n8716048