December 9, 2018

Does Fair Value Even Mean Anything?

Does Anyone Care About Fair Value Anymore?

Fair value is a simple enough concept even if you aren’t an accountant: stuff is worth what you could sell it for in the normal course of business, so that’s what you value it as when you’re adding up the value of the stuff you have. Easy, right? Not so easy when it comes to convergence.

The IASB has already expressed distaste for our fair value rules (among other things) and Accounting Onion recently shared some concerns that convergence might require a reasonable definition of “High Quality Accountant Standards” (abbreviated HQAS” by AO) agreed upon by both FASB and the IASB. So far I haven’t seen it, has anyone else?

Wait, AO launches off into it fhan I ever could.

Moreover, if there are some doubts as to what HQAS is, the SEC’s view could have been attended to more closely at the outset of formal convergence efforts (October 2002); for surely the SEC had convergence in mind when they published their congressionally mandated (see the Sarbanes Oxley Act, Section 108(d)) report on the feasibility of “principles-based” accounting standards in August 2003. According to the SEC, the “objectives-oriented” standards they are looking for from a standard setter should possess the following qualities:

“Be based on an improved and consistently applied conceptual framework;

Clearly state the accounting objective of the standard;

Provide sufficient detail and structure so that the standard can be operationalized and applied on a consistent basis;

Minimize exceptions from the standard;

Avoid use of percentage tests (“bright-lines”) that allow financial engineers to achieve technical compliance with the standard while evading the intent of the standard.”

Now, seven years later, the SEC’s battle plans have been subordinated by the din and desperation of convergence wars. Are any new standards from either board “based on an improved and consistently applied conceptual framework”? Obviously not, for nary a single alteration to any conceptual framework document has occurred in the last seven years. The existing definitions for assets and liabilities are like wooden ships sent to battle against nuclear submarines.

A few weeks back, I talked to David Larsen, CPA, Managing Director of global advising firm Duff & Phelps, LLP about this fair value bullshit that complicates my life by requiring comment every few weeks. David participated on the SEC mark-to-market panel in November of 2008 and serves on FASB’s Valuation Resource Group so he’s familiar with what I’m talking about.

David believes public opinion dominates the fair value argument and really doesn’t see what the big deal is. “The goal is to make financial statements more readable,” he said of fair value’s ultimate intention. He’s a fan of transparency on the face of financial statements and more disclosures. Who doesn’t like that?

He says fair value is purely measurement and disclosure, nothing to get upset about.

In my opinion, fair value was our first test to see if we could handle the principles widely used in international accounting “standards” (hopefully “HQAS”) before we actually committed to adopting them and we failed. If you wonder why the IASB wants to hold the floor when it comes to convergence, you only have to stare our treatment of fair value right between the eyes.

It should have worked but our “P for Principles” in GAAP didn’t adequately prepare us to handle it.

Can We Stop Pretending That Fair Value Convergence Is Possible?

FASB IASB.jpgAnyone okay if we just called this whole convergence thing off? Seriously. We understand that many accountants are perfectionists but healthcare reform seems to have a better chance than this whole shitshow.
Yesterday’s Wall St. Journal claims that the FASB’s biggest wig, Bob Herz is stating, albeit implicitly, that the FASB’s fair value rule will be more strict than the IASB’s. Herz-dog, being a little more political put it this way:
Pleasant disagreement, after the jump

“I hope we can come up with something that both achieves convergence and improves the current state” of accounting rules, Herz said at a roundtable discussion on the fair-value issue at FASB headquarters. “We’re obviously keenly aware of the difficulties of achieving both goals together.”
Herz later said in an interview that while FASB would do its best to harmonize its approach and the IASB’s, “we also want to make sure we come up with a good answer” to improve financial statements that U.S. investors look to.

That’s about as combative as The Herz gets, although, we, like the Journal, will take any chance we can get to embellish otherwise, yawn-worthy comments made by wonky accounting bureaucrats.
More:

John Smith, an IASB member who also participated in the roundtable, said both boards will try to agree on a fair-value rule, but each has its own process to follow, and “at the end of the day, we won’t know until we finish the process.”
The difficulty in harmonizing the two approaches stems from the sharp disagreements over expanding the use of fair-value accounting. Smith called it “a religious war.”

Okay, so we’re not really convinced these guys give a damn either way if accounting rule convergence occurs, especially fair value. So would everyone just knock it off and quit pretending like it’s so bloody important?
Besides, this is a “religious war”. And everyone knows that wars in the name of the Almighty (in this case, GAAP) NEVER end, so let’s just count on this being unresolved through the next millennia.