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How was I not aware, until now, that what looks like a full RSS feed for Justin Fox's excellent Curious Capitalist blog actually isn't? He didn't write 314 words on the pros and cons of marking to market: in fact he wrote 1,262. And they're well worth reading, as you might expect from the author of a 320-page book on the efficient markets hypothesis.

Fox has a much more nuanced view of marking to market than most of the econoblogosphere, which has tended to knee-jerk dismay at the prospect that the SEC might suspend mark-to-market accounting. Yes, says Justin, mark-to-market is probably better than the alternatives, but that doesn't make it very good: what we really need here is a healthy dose of realism when it comes to the usefulness of any single number.

The health of a bank or any corporation can never be adequately measured by a single bottom-line number. Understanding the assumptions and uncertainties inherent in accounting numbers is crucial to understanding how to use them.

What's more, the old problems with the absence of mark-to-market accounting are not necessarily going to reappear if it's suspended. The S&L crisis, for instance, happened when interest rates rose sharply, and banks which had extended 30-year mortgages at 6% found themselves paying double-digit interest rates on deposits. In Justin's words, they "became what's known as zombie banks, lurching across the landscape running up ever bigger losses," and they were able to do so because they marked their mortgages at par, rather than discounting them at prevailing interest rates.

But what we're looking at now is not a reversion to the state of affairs where banks can stop marking their assets to market and start simply declaring them to be worth 100 cents on the dollar. Instead, they'll mark to a model which not only involves discounting at prevailing interest rates (which alone would have prevented the S&L problem) but also tries to account for expected default rates as well.

Will such models prove more accurate, over time, than market prices? No one really knows. But already we've reached the point at which the markets are displaying a healthy sketpicism about accounting numbers, even when they're generated on a mark-to-market basis. That skepticism was ultimately responsible for not only the downfall of Lehman Brothers (LEH) (which, remember, was solvent on a mark-to-market basis, or so its balance sheet said), but also the conversion of Morgan Stanley (MS) and Goldman Sachs (GS) to bank holding companies.

The market has already spoken: it would rather see investment banks regulated by the Fed than trust those banks' internally-generated mark-to-market numbers. If the banks start reporting numbers based on some other standard, trust won't increase at all. But it might not go down much, either.

All the same, the best thing I can say about suspending mark-to-market accounting is that the downside is slightly more limited than some people might think. I still can't see any upside, and I don't think Justin can, either. Given the choice, I suspect that healthy institutions will continue to mark to market -- and that investors will reward them for doing so, and punish those who mark to anything else.

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This article has 8 comments:

  •  
    The problem is not mark-to-market as an accounting tool. The problem is mark-to-market as a regulatory tool. Regulators apply rules. If MTM shows you're insolvent by their rules then you're insolvent and that's just the way it is. Even if, in reality, you're not.
    2008 Oct 02 03:26 PM | Link | Reply
  •  
    Let's give companies a choice - per assets class they choose M2M or Mark to Fantasy.

    Just one rull;
    market to fantasy assets need to be specified to line level on the balance sheet.

    Management can in the side letter explain why those assets bear a high value than the current market price tells them. We investor can go through the line items and make our own assessment.

    Accounting firm sign off on the accurateness of the descripition of the line items - not on the Mark to Fantasy value.

    Problem solved for the investors and for credit market.

    Problem remains for the regular to determine solvency levels of banks. I agree with that - but at least we solved the issue for the first two domains.

    2008 Oct 02 06:19 PM | Link | Reply
  •  
    The assets had to be evaluated quarterly and an allowance provided if the value decreased. the allowance was the problem if it had to be barrowed in a tight market and this was what drove them out of business. The government is willing to take these assets and keep them without M2M indefently. Well let them stay with the banks on the same basis and the problem is over. There will be writedowns as they become worthless for the banks and not us taxpayers.

    2008 Oct 02 06:44 PM | Link | Reply
  •  
    Um, I believe the SEC just "clarified" the m2m rule to risk and cash-flow based discounting for illiquid markets... That would be an end to the very thing that caused $500B of write-downs and $5T in lost lending capacity...

    Oh yeah, and what about the lifting of $5.6T of assets from sharedholders and the redistribution of those to banks...? Had Tuesday's "clarification" existed November 15, 2007, none of these banks would have failed.

    You have all been the unwitting victims of the largest fraud ever to have been perpetrated in the history of the world.
    2008 Oct 02 06:49 PM | Link | Reply
  •  
    Why is it that the SEC is appearing on the top of everyone's shI** list?
    2008 Oct 02 10:34 PM | Link | Reply
  •  
    The heat is on and the US once again, consistently, will try to change the rules. Moral dilemma: What are we teaching the next generation of kids? The mark to market rule was there for the same exact reason which is to avoid this floundering crisis. So much money allotted to bail white collar crooks; not a single cent to help rebuild New Orleans. America, wake up!
    2008 Oct 03 03:10 AM | Link | Reply
  •  
    the m2m will help the financials in this case as soon as the bailout is passed - why because Paulson is going to overpay for illiquid assets in order to get those m2m way up -it will be a smoke and mirror job but it may work -I cannot see Buffett going in the market for the economy's health- he sees profit and goldman and GE are his bets - citigroup looks like a gem in this scenario as well as chase and bank of america
    2008 Oct 03 04:02 AM | Link | Reply
  •  
    Accounting statements are intended to provide "useful" information to statement users. In an attempt to provide useful information and prevent lawsuits and dismemberment ala Arthur Anderson, the FASB and the accounting industry opted to support the MTM principal. Like a lot of things in life, it did not go as planned. When the market locked up, this methodology gave ridiculous numbers for the value of financial instruments. "Models", which have been given such a bad image by the media, turn out to be better indicators of value when markets are inefficient. A standard model, frequently used in M&A as well as plain vanilla commercial real estate transactions, is to value the asset at the contracted cash flows discounted by the prevailing interest rate. An allowance based on recent historical results is used to reduce overall portfolio value for anticipated defaults (net of collateral salvage value). The MTM concept in an illiquid market is like taking your own single hone mortgage note out on the street and trying to sell to passerbys. Likely there will be no takers. Does that mean the mortgage note is worthless? Of course not. A portfolio of collateralized mortgage notes has some value. The goal is to find a reasonable number that is "useful." Zero is neither reasoable nor useful.
    2008 Oct 03 09:41 PM | Link | Reply
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