Tom’s Ten Data Tips – October 2010
New Accounting Standards
Financial
accounting has traditionally been a mix of formality and fluidity. Some rules
are quite rigid, and they're enforced using complex and detailed guidelines. At
the same time, interpretation can be "fluid" as when interpretation is adapted
to meet business needs. Market pressure has raised the needs for standards that
are better aligned with business needs, yet at the same time provide
consistency and control required to ensure reliability and comparability.
In
2005 new IFRS reporting standards were introduced for public companies ("full
IFRS"). These were followed in 2009 by an IFRS standard for private companies.
About 100 countries in Europe, South America and
Asia
are now using IFRS. One of the objectives is to increase transparency of
financial reporting, which fosters confidence of investors. Yearly reports
should become more comparable. Stakeholders demand better internal controls,
better corporate governance, and insight in results.
1. Accounting Is Not Exact Science
Although
many lay people assume that accounting is exact, bound by clear rules and
guidelines, experience shows it isn't. Because judgment plays such an important
role, the question may arise how to enforce "proper" accounting rules. Auditors
find clarity and comfort in rulings, as their work can hardly be challenged
(when conducted ethically). There is much less certainty in a principles based
system.
Traditionally
the American system has been regulated more by explicit rules pertaining to
clearly defined domains. New IFRS standards, on the other hand, are principles
based. They provide guidelines that should be followed. Specification about
what exactly is or is not allowed arises as individual cases or examples are reviewed
and/or brought to trial.
2. Accountancy Rules Impact Financial
Stability
The
London
based
International Accountancy Standards Board (IASB) has been in charge of
reworking the rules that cover financial reporting. After the recent financial
crisis, regulators are keen to (re)establish financial stability. Basel III has
been directed towards this same goal.
In
particular marking at "fair value" (=market prices) remains controversial. The
intent of that rule change was to improve transparency. Because assets move
along with market dynamics, it should make clear how much a company's holdings
are 'really' worth, at any given pointing time. During the meltdown, this
mark-to-market practice triggered massive swings due to write-offs,
exacerbating the effects of the crisis because capital buffers evaporated (in
particular greatly leveraged assets). "Fair value" pricing proved especially
tricky for assets that aren't traded frequently enough, or where "market
prices" aren't publicly available. When the only available market prices are
from distressed sales, they undervalue
these assets, reinforcing this loop and potentially contributing to
instability.
3. It's Not
Investors Or Regulators, But And/And
Some
of the "political" debates on accountancy rules reforms suggest (or at least
imply) that rules either support
investor interests or protect
regulators' interests. As if this is a zero sum game. It isn't. Clear
information attracts investors, and thus raises stock prices by increasing the
pool of interested buyers, as well as lowering the cost of capital. Transparent
rules that are uniform across the globe are in investors' best interest.
Regulators, from their part, need global rules so that policies can actually
"work", and not chase multinationals to move their activities in accordance
with local or regional advantageous rule setting.
A
whole different question is how politicians' involvement (which seems only fair
after scandals in recent years) should be juxtaposed against the necessary
independence of standards setters. Setting rules that can be executed, enforced
and audited is (largely) a technical matter, albeit one that might affect
politicians at the helm
4. Accounting Standards ≠ Auditing Standards
Because
accounting is so closely associated with auditing, it isn't surprising that
their standards are sometimes confused. Apart from the fact that separate and
independent boards set these standards, they have a rather different basis as
well. For the
US
the
Financial Accounting Standards Board (FASB) has overseen US GAAP (Generally
Accepted Accounting Principles),
Europe
has
the International Accounting Standards Board (IASB). The International Auditing
and Assurance Standards Board (IAASB) sets international
standards for auditing (ISA's).
The
essential difference between auditing and accounting is that accounting standards are in essence
algorithms: they stipulate which numbers should be added, subtracted and
divided, etc. Auditing standards, on the
other hand, are guidelines on how to behave, e.g.: how to check whether books can "pass" or not.
5. Adoption Of
XBRL Expedites Financial Consolidation
Considerable
(data) integration work goes into producing financial reports. Especially in
large companies, multiple ERP systems may be in use. Several financial systems
may be in place. When XBRL has not been adopted, yet, chances are that
financial results have not been booked consistently across business units
(BU's). Line items of financial transactions then first need to be "normalized"
into a common set of definitions. After consolidation across systems and/or
BU's has taken place, you might need to include non-financial items like
budgets, head count, or changes on stock. Finally, these are combined into
financial reports for internal management and control, external reports, and
maybe regulatory requirements.
To
make all these mappings and consolidations consistent and robust, some meta structure is required. You can integrate this structure
by embedding it in all (financial) reporting tools. A common framework has been
devised, and it's called XBRL (see also a previous
newsletter). XBRL is geared to the differential reporting requirements across
multiple internal and external
stakeholders.
6. How 'Fair' Is "Fair Value" Accounting?
One
of the cornerstones of IFRS accounting innovation is "fair value" accounting.
Previously, companies would record assets at the price they were bought
(historical cost). Under "fair value" accounting, the market price should be
used, which is commonly referred to as "mark-to-market" pricing. This should be
an unbiased estimate of the current market price. Under US GAAP (FAS 157), this
explicitly excludes liquidation sales.
Assets
that are infrequently traded show (relatively) big swings in their prices. When
the "market price" trails the 'true' (rational) value, a gap arises between the
technically defined "Fair Value", and the observed "market price." This has
been the center of much heated debate on the current accounting innovations.
7. "Off-Balance Sheet Entities" Exist
Anyway
For
an outsider, it seems counter intuitive how assets that are held by a company,
and may contribute to liabilities can be moved on and off a balance sheet. The
now infamous "Repo
105"
deals by Lehman Brothers
were such a move that in hindsight appeared to be largely driven by attempts
at window dressing (Lehman's Repo's flattered the
accounts because they suggested lower leverage ratios). Only after their collapse which sent a
shockwave through international markets did the "true" nature of some of these
deals become clear.
Needless
to say, what assets must, or need not be reported is determined by accountancy
rules. Which is exactly why the current changes in rules is
making some (in particular very large) companies so nervous. Newly proposed
IASB rules require greater disclosure of these off-balance sheet entities.
Leasing is another one of those off-balance constructions that is hotly
debated. Isn't it odd that airlines don't have airplanes on their balance
sheets (they're all leased)?
8. You Can't Make It Any Simpler Than It
Is
IFRS
has been criticized for making results more difficult to interpret. There are
certainly more numbers that need to
be reported. Reports have gotten markedly thicker. And their meaning is not
very clear to most outsiders.
Another
way of looking at this, is by concluding that the
desired transparency calls for increased complexity, simply because telling the
whole truth is complex. As Einstein
said: "Everything should be made as simple as possible, but not simpler."
9. Will We Live To Tell "Real-Time" Accounting?
There
is a disconnect between publishing results in the rhythm of our Gregorian
calendar, and the more dynamic, fluid manifestation of a company's financial
well-being. Current reporting practices, in conjunction with shareholder
dynamics of publicly traded companies effectively "force" CFO's to "iron out"
set backs and gains. This effectively (in part) conceals their operations
rather than disclosing them.
In
the internet era, and technologically facilitated by XBRL (See tip# 5), we have
come to expect information anywhere, anytime, at the tips of our fingers. Then why not for accounting? The big four accounting firms (PwC, Deloitte, KPMG, and Ernst & Young) have made calls
for this. And XBRL makes this (technically) possible. It would also allow for
simultaneous presentation of broader as well as simpler measures to report on
companies' well-being.
10. Which Are Safer: Rules Or Standards?
Historically,
accounting has been rule-based. The introduction of IFRS marked a change
towards principles based accounting. This makes work a bit more uncertain as
accountants themselves are then responsible for judgment and interpretation.
Accountability needs to be contained within the profession and pushed back, all
the way up to the CFO. The
US
has had a history of rules based accounting, and much more involvement from
lawyers. Introduction of the Sarbanes-Oxley ruling (SOX, in particular sections
404, 406 and 407) makes CEO's of US listed public companies responsible for the
accuracy of their reports. A defense line "I didn't know about this!" (even if it were true) will not keep you out of jail.
One
reason why principles based accounting has caused sleepless nights is because a
mishap can lead to a damages claim. That would be devastating for any accounting
firm, and could ultimately destroy it or at the very least undermine it's brand. Principles put responsibility for judgment where
it belongs: with the accountant. Whether they like this or
not.
Further reading
Some
excellent books on New Accounting Standards:
Smoke & Mirrors, Inc.
Nicolas
Véron, Matthieu Autret & Alfred Galichon
(2006)
ISBN#
0801444160