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  • 24 Aug 2010 at 1:45 PM
  • MBAs

“Other Than That, I Have No Concerns”m

To: Dealbreaker

From: [redacted]

Subject: FASB Comment Letters spreading around Firm

As you know the FASB has exposure drafts out that introduce the notion that banks should write down all their loans to fair value every quarter (remember the recession) and the comment letters are trickling in. A couple of them are classic. For your reading pleasure… Who knew writing a comment letter required technical savvy. Let’s tell the accounting gods in CT what we really think…

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  • 02 Apr 2009 at 1:59 PM

The Making Of Sausages

FASB doesn’t do its rule making in a vacuum. It solicits (and mostly ignores) comments from a wide range of stakeholders. The result is a rich set of data to examine the role of large institutions in shaping the rules that govern them. The result is language like this:

We believe that certain aspects of the proposed FSP fail to meet the Board’s objective and would, in fact, increase the difficulties experienced by preparers and auditors by limiting the number of data points that preparers may consider in making valuation estimates. In addition, we are concerned that the example provided in the proposed FSP is confusing and may lead to conclusions that are not consistent with the concepts and framework of Statement 157, further resulting in significant inconsistencies in the fair value measurements estimates for the same financial instruments among various preparers.

Which should properly be read as “This fucking mark to market stuff is killing us!”
Deutsche Bank Letter To FASB, March 27, 2009.
SIMFA Letter To FASB, March 27, 2009.
Citi Letter To FASB, March 30, 2009.

  • 30 Sep 2008 at 4:12 PM

Kicking It With The FASB

A review of “fair value” accounting promises to be a long, painful procedure that not only carries with it the possibility of severe and potentially deadly infection, but entails a long recovery time and is likely to reveal any number of other tumors and growths that threaten to be a bigger deal than the original concern.
Accounting pathologists that we are, our attention has been rapt.
Take a seat in the visitors observation lounge. We’re going in.

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Earlier this morning we discussed how changes in the way accounting rules treated auction-rate securities helped drive corporate investors out of the market. (For a rousing debate of exactly which accounting changes stamped out demand, click here.) Credit market concerns and the changes in the way auction-rate securities are treated on cash flow statements contributed to the rush out of the securities by bringing additional scrutiny to the once obscure financial instruments. At the end of 2007, many companies made the decision to shift assets out of auction rate securities as these changes were implemented for the new fiscal year.
The Apollo Group owned as much as $365 million in ARS at the end of 2007, according to a recent filing. But by February 19, 2008, all but $107 million of the ARS investments had been liquidated and not reinvested in the ARS market. Apollo says this well-timed exit was part of a plan to intentionally reduce its exposure to the auction rate securities, although they do not reveal what prompted the exit. The timing wasn’t perfect, however, and Apollo found itself unable to liquidate approximately $79 million in ARS due to auction failures.
Despite not completely exiting the ARS market, we’ll count Apollo a winner. So who’s still holding the securities? After the jump, we reveal two companies trapped by the auction failures.

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