Highlights of SEC mark-to-market roundtable

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26 Nov 2008

On 21 November 2008, the US SEC hosted its second and the final roundtable on fair value or mark-to-market (MtM) accounting. The SEC's study of MtM accounting is mandated by the Emergency Economic Stabilization Act of 2008. The roundtable focussed on challenges of MtM accounting and potential improvements to accounting standards. The roundtable consisted of investors, issuers, auditors, and others with experience in MtM accounting.

Here are preliminary and unofficial notes taken by Deloitte observers at the Roundtable:

The general consensus of the panel

The general consensus of the panel was that fair value accounting under Statement 1571 is not the root cause of the current market turmoil. Panelists indicated that regulators should look beyond Statement 157 to address some of the issues prevalent in practice today, such as changing the regulatory capital requirements. In addition, the panelists voiced strong support for independent standard setting, noting that the process needs to be free from any political or regulatory intervention.

Three main themes from the discussion

Impairment guidance The panelists agreed that standard setters should revisit other-than-temporary impairment guidance. Several suggestions were made, including (1) to align the guidance for impairment of investments in debt securities (Statement 1152) with the guidance for loan impairments (Statement 1143) and (2) to segregate impairment loss between credit and other changes in fair value. Panelists from the investor and auditor community suggested a model in which credit loss on debt securities would be recognised currently in income, and other changes in the fair value of the instrument (the plug) would be recognized in other comprehensive income. The credit loss would be calculated on the basis of changes in expected cash flows in a manner similar to the Statement 114 model. Several panelists from the preparer community suggested that the investments should be carried at amortised cost so that only losses associated with credit are recognised and the fair value of the instrument is disclosed in the notes to the financial statements on a quarterly basis. They indicated that recognising liquidity losses in other comprehensive income distorts equity, which affects regulatory capital requirements.

Additional disclosures Panelists agreed on the need for (1) more comprehensive disclosures that may include forward-looking information (such as sensitivity analysis) and (2) detailed discussion of techniques and inputs used by management to estimate fair value. Certain panelists suggested that additional disclosure requirements should be provided by regulators or standard setters before year-end financial reporting.

Presentation Panelists agreed that improved income statement presentation of fair value measurements would enhance the transparency and usability of financial statements by the investor community and that the FASB should consider improving financial statement presentation as part of a long-term project.

1FASB Statement No. 157 Fair Value Measurements
2FASB Statement No. 115 Accounting for Certain Investments in Debt and Equity Securities
3FASB Statement No. 114 Accounting by Creditors for Impairment of a Loan

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