TheBookkeeper

Citigroup, Merrill Lynch, Citadel: Earnings Troubles All Around

You said:
"Tighten, don't loosen, accounting rules for financial institutions,"

Surely you know, sir, that the rules that accounting must follow are the 650 year old double-entry book-keeping framework of rules, no? If banks had been accounting to those rules the nation would not be where it is today.

"making them mark-to-market financial asset portfolios that specifically cannot be held on a long-term basis. Also clarify rules around consolidation of off-balance sheet vehicles,"

There is no legal 'off balance sheet vehicle.' A book-keeper's job is to administer contracts with transparency to all entities that are parties to the contract, and that surely includes stockholders. If a vehicle is placed off the balance sheet then any obligations an entity has to that vehicle's contract belongs on the entity's balance sheet. This is book-keeping 101, which is to identify an entity's boundaries of contractual obligations. aka "rights to ownership."

"forcing all but the most clearly dissociated entities to be recorded as on-balance sheet obligations."

There is no "all but." There is either a contractual obligation or there is not an obligation. All else is fudged books. Banks are failing because they are not doing their bookkeeping. An accountant is not a bookkeeper. Accounting and bookkeeping interests are as different as the baseball pitcher and the umpire who is calling balls and strikes.