Dillip Khuntia

Master of
of Finance
Finance & Control
Utkal University
University
INTRODUCTION

The need for a reform of the accounting treatment of financial instruments stems from
several market developments. Financial innovation has blurred the distinction between
financial instruments and has contributed to the development of markets for instruments that
were traditionally considered as illiquid and non-tradable. The rationale for the different
accounting treatment of banking, securities and insurance services has gradually disappeared
as they often serve the same economic function. Moreover, as financial institutions have
increased the range of services they provide, so mixed accounting systems have been
developed that do not seem sustainable in the long run.

As the trading and capital market-related activities of banks have grown, the
accounting framework has been modified to permit market valuations for all the instruments
held for trading purposes. The coexistence in banks’ financial statements of items valued at
historical costs (which are mainly held in the so-called “banking book”) and others at market
values (in the “trading book”, which is “marked-to-market”) would be viable only if banks
were managing the two components of the bank portfolio in a totally segregated manner. But
this is not the case, as trading instruments are increasingly used to hedge the interest rate risk
in the banking book. More importantly, the increased reliance of financial institutions on
derivatives contracts, which in most jurisdictions are recorded as offbalance-sheet items, has
contributed to a growing misalignment between the information contained in financial
statements and the true risk profiles of reporting entities. Even supervisory authorities and
central banks are often lacking information on the effective redistribution of risks resulting
from the extensive use of derivative instruments such as credit derivatives. Current disclosure
requirements are not deemed to be adequate to cover this information gap. An improvement
in the quality, coherence and information content of financial statement therefore seems
necessary in order to reflect the new financial environment and thereby favour a proper
monitoring of management’s behavior by stakeholders.

This paper explains the fair value accounting as per FAS 157 prescribed by the FASB
and also explains the fair value accounting as per IAS 139 issued by IASB. A note on
evolution of fair value concept is also mentioned along with its advantages and lacunae. The
use of the fair value accounting along with a case study is also given.

BACKGROUND
 The United States was the pioneer in the application of fair value, with the appearance
in 1992 of SFAS 107. With this standard the FASB obliged institutions to publish the fair
value of all their financial instruments in notes to the financial statements. This included the
valuation of the portfolio of loans, deposits and any other off-balance-sheet items banks could
contract. Moreover, SFAS 115 obliged institutions to include the fair value of some of their
negotiable securities on the balance sheet and profit and loss statement. Although the
standards were criticised by the banking industry and banking supervisors, standards in other
countries moved in the same direction. Thus, in the United Kingdom the Accounting
Standards Board published a consultation document in 1996 in which it concluded that the
mixed model was not satisfactory, proposing instead the valuation of all financial instruments
at their fair value.

The International Accounting Standards Committee (IASC), later replaced by the

International Accounting Standards Board (IASB), joined this trend in 1999 with issuing of
an accounting standard (IAS 39, Financial instruments: recognition and measurement) which
required the use of fair values in the case of certain financial instruments, particularly
derivatives, as well as shares and other securities, whether held for trading purposes or for
sale. This standard, which was to have particular impact on financial institutions, was sharply
criticised and was felt to be premature.

In December 2000 the accounting standards bodies' Joint Working Group (JWG), on
which both the IASB and national accounting standards bodies were represented, proposed an
integrated and harmonised standard for the application of fair view to all financial
instruments, including deposits and loans and independently from the purpose for which they
were held. This proposal to make full use of fair value was greeted with scepticism by the
banking sector and investors. The standard was not adopted, but the trend towards the more
general use of fair value was not abandoned. In August 2001 the IASB began a project to
modify IAS 39. In 2002 it published a draft proposal, together with a call for comments.
After the criticism received, in August 2003 a new draft proposal was published for public
consultation and in December 2003 the IASB published the revised version of IAS 32
(Financial instruments: disclosure and presentation) and IAS 39 (although small
modifications have since been made).

FAIR VALUE ACCOUNTING BASED ON SFAS 157

 SFAS 157 details the framework for measuring fair value for firms reporting their
financial statements based on US GAAP. Prior to this standard, there were different
definitions of fair value, and limited guidance in the applications of those definitions. SFAS
157 provides a consistent definition of fair value, outlines several types of valuation
techniques that can be used to measure fair value, and requires firms to disclose their
valuation inputs (the “fair value hierarchy”), in order to increase consistency and
comparability in fair value measurements.

The standard defines fair value as “the price that would be received to sell an asset or
paid to transfer a liability in an orderly transaction between market participants at the
measurement date”. This definition focuses on the price that would be received to sell the
asset or paid to transfer the liability (“exit price”), not the price that would be paid to acquire
the asset or received to assume the liability (“entry price”). An orderly transaction assumes
that the firm has sufficient time to market the asset. Hence, fair value estimates should not be
estimated as in a forced liquidation or distress sale, contrary to some misconceptions about
fair value accounting.

SFAS 157 states three valuation techniques which can be used for estimating fair
values. They are the market approach, income approach, and/or cost approach (paragraph 18).
A market approach typically uses quoted prices in active markets, but other valuation
techniques consistent with the market approach include the use of market multiples derived
from a set of comparables, and matrix pricing that allows a firm to value securities without
relying exclusively on quoted prices.

The second approach is the income approach. The income approach uses valuation
techniques to convert future amounts (cash flows or earnings) to a single present value
amount. Examples of such valuation techniques include present value discounted cash flows,
option pricing models (for example, the Black– Scholes–Merton formula, or a binomial
model), and the multi-period excess earnings method. Finally, the cost approach is based on
the amount that would be required to replace the service capacity of an asset. From the
perspective of a seller, the price that would be received for the asset is determined based on
the cost to a buyer to acquire or construct a substitute asset of comparable utility, adjusted for
obsolescence such as physical, functional (technological), and economic (external)
obsolescence.
 SFAS 157 establishes a fair value hierarchy that prioritizes the inputs to valuation
techniques that are used to measure fair value. Broadly speaking, inputs refer to the
assumptions that market participants would use in pricing the asset or liability, including
assumptions about risk. The standard specifies the use of valuation techniques that maximize
the use of observable inputs (i.e., based on market data obtained from sources independent of
the firm), and minimize the use of unobservable inputs (i.e, inputs that reflect the firm’s own
assumptions as to how market participants would price an asset or liability).

Specifically, a firm is to use Level 1 inputs (unadjusted quoted prices in active

markets) on the assumption that a quoted price in an active market provides the most reliable
evidence of fair value. It shall be used whenever available (paragraph 24), except when it is
available but not readily accessible (paragraph 25), or when it might not represent fair value
at the measurement date (paragraph 26). If observable prices are not available, the firm can
value its assets based on Level 2 inputs (observable inputs other than quoted prices included
within Level 1). Level 2 inputs are inputs such as (i) quoted prices for similar (but not
identical) assets or liabilities in both active and inactive markets, and (ii) inputs other than
quoted prices such as interest rates and yield curves, credit risks, default risks, and other
inputs that can be derived principally from observable market data by correlation, or other
means (market-corroborated inputs). A Level 2 input must be substantially observable for the
full term of the asset or liability.

Finally, to the extent that observable Level 2 inputs are not available (for example,
situations in which there is little market activity for the asset or liability at measurement
date), Level 3 inputs can be applied. These are the firm’s own assumptions about how other
market participants would price the asset or liability. To ensure that there is information that
will enable financial statement users to assess the quality of inputs used to estimate these fair
value measurements, the standard requires firms to disclose information (separately for each
major category of assets and liabilities), both quantitative information that shows how the fair
value measurements are segregated based on the valuation inputs, and qualitative information
that details the valuation techniques used to measure fair value. The quantitative disclosures
are to be presented in tabular format.

FAIR VALUE ACCOUNTING BASED ON IAS 39

IAS 39 details the principles for recognizing and measuring financial instruments for
firms that report their financial statements under IFRS. IAS 39 defines fair value slightly
differently from SFAS 157. Fair value is defined as “the amount for which an asset could be
exchanged, or a liability settled, between knowledgeable, willing parties in an arm’s length
transaction”.

There are some subtle language differences between the fair value definition in SFAS
157 versus that in IAS 39. SFAS 157’s definition is explicitly based on the concept of an
“exit price,” whereas IAS 39’s definition is based neither on “exit price,” nor “entry price.”
SFAS 157 uses the “market participants” view whereas IAS 39’s definition uses the concept
of “willing buyer and seller.” SFAS 157 states that the fair value of a liability is the price that
will be paid to transfer a liability, whereas IAS 39 defines the fair value of a liability as the
amount for which it can be settled. The IASB has asked for respondents’ views on these
differences.

As with SFAS 157, IAS 39 states that fair value estimation is not the amount that a
firm would receive or pay in a forced transaction, involuntary liquidation, or distress sale
(paragraph A69). Also consistent with SFAS 157, IAS 39 regards the best evidence of fair
value as quoted prices in an active market. Finally, while IAS 39 does not explicitly classify
valuation inputs into Level 1, Level 2, and Level 3 categories as specified in SFAS 157, it
does specify that the chosen valuation technique should make maximum use of market inputs
and rely as little as possible on firm-specific inputs.

Regarding the measurement issues relating to fair value estimation, IAS 39 provides
three classifications: Active markets for which quoted prices are available, inactive markets
for non-equity instruments, and inactive markets for equity instruments. For financial
instruments trading in active markets, the appropriate quoted market of an asset held (or
liability to be issued) is the current bid price, whereas for assets to be acquired (or liability
held), it is the current ask price. When current bid and ask prices are unavailable, the price of
the most recent transaction can be used provided that there has not been a significant change
in economic circumstances since the time of the transaction. Furthermore, quoted prices can
be adjusted if the firm can demonstrate it is not fair value (for example, distress sales).

In the absence of an active market for a non-equity financial instrument, IAS 39

specifies that the preferred valuation technique to be used is the valuation technique that is
shown to be commonly used by market participants to price the instrument (for example, if
the valuation technique has been demonstrated to be able to provide reliable estimates of fair
value obtained in actual market transactions). The chosen valuation technique needs to be
consistent with established economic methodologies for pricing financial instruments, and the
firm needs to calibrate the valuation technique periodically by testing it for validity using
prices from any observable current market transactions in the same instrument (or based on
any available observable market data).

Finally, for equity instruments (and any linked derivatives) that do not have a quoted
market price in active markets, IAS 39 specifies that these instruments are to be measured at
fair values only if the range of reasonable fair value estimates is not significant, and the
probabilities of the various estimates can be reasonably assessed. Otherwise, the firm is
precluded from measuring these instruments at fair value.

ARGUMENTS IN FAVOUR OF FULL FAIR VALUE

The so-called full fair value model proposes accounting for all financial instruments at
fair value, and registering any variations in their value immediately on the profit and loss
account. Valuing all financial instruments by their fair value will allow users of financial
statements to obtain a truer and fairer view of the company's real financial situation as only
fair value reflects the prevailing economic conditions and the changes in them. By contrast,
historical cost-based accounting shows the conditions that existed when the transaction took
place and any possible changes in the price do not appear until the asset is realised.

Moreover, the widespread application of fair value offers a more consistent and
comparable valuation framework, as instruments are valued at the same time and according to
the same principle. The traditional model, on the other hand, does not allow comparisons to
be made easily. Two companies with identical financial instruments, the same cash-flows and
risks, could show different values on their financial statements according to the moment in
time when they bought them.

Defence of the full fair value model is draws upon the criticisms that may be leveled
against the mixed valuation model, where some instruments are recorded at historical cost
and others according to their fair value. In the mixed model the criteria for valuing an
instrument at its cost or market value do not depend on the characteristics of the instrument
but on whether the institution intends to hold it long term or trade it; this is closely related to
the distinction between the instruments pertaining to traditional banking activities (the credit
portfolio) and the proprietary trading portfolio.
 Thus, if the mixed model is applied, identical instruments may be valued differently
and have a different effect on the balance sheet and profit and loss statement. Moreover, the
separation between the credit portfolio and the trading portfolio may vary from one
institution to the next, and therefore make it hard to compare financial statements.

Lastly, the mixed model creates opportunities for a degree of accounting arbitrage,
that is to say, that the classification rules might be interpreted so as to categorise assets and
liabilities so that it is possible to apply the most beneficial valuation criteria, in detriment to
the quality of the information and, in short, the ability of financial statements to reflect the
economic reality of the institution objectively and reliably,

CRITICISMS OF THE FAIR VALUE MODEL

There is a fairly wide consensus as to the appropriateness of applying the criteria of

fair value to instruments held in the trading portfolio. Nevertheless, this method is forcefully
rejected for the valuation of the credit portfolio and financial liabilities. In order to be useful
as the basis for rational economic decision-making, financial information must be relevant,
reliable and comparable. The criticisms focus on these characteristics and the impact using
the fair value method would have on the stability of the system as a whole.

USE OF FAIR VALUE

Fair value is a required measure for many financial instruments. Determining whether
a financial instrument should be recorded at fair value in a company’s financial statements
depends in part on what type of institution owns the instrument and the intended use of that
instrument. For example, in the case of a broker-dealer, a high percentage of its assets
typically are traded and must therefore be accounted for at fair value. Other institutions
record financial instruments at fair value depending on what their intent is for holding the
instrument or the nature of the business activity. If an institution decided to hold a U.S.
Treasury bond to maturity, for example, the bond can be shown at its original cost. If the
institution purchases another identical Treasury bond that it intends to sell in the near future,
that bond would be accounted for at fair value.

In addition to using fair value measures to comply with public reporting requirements,
companies measure their financial instruments at fair value for a number of internal
processes, including: making investing and trading decisions, managing and measuring risks,
 determining how much capital to devote to various lines of business, and calculating
compensation. The use of fair value measurements is deemed to be relevant in these areas.

RECENT CHANGES TO FAIR-VALUE ACCOUNTING UNDER US GAAP AND

IFRS

On 30 September 2008, the Office of the Chief Accountant of the SEC and FASB
jointly issued a press release with immediate clarifications on fair-value accounting rules in
light of the financial crisis (recent guidance). On 10 October 2008, the FASB issued a staff
position further amplifying that press release. The International Accounting Standards Board
(IASB), the EU equivalent of the FASB, quickly responded to the SEC announcement to
confirm that IAS 39 was consistent with SFAS 157 and that it will continue to ensure that any
IFRS guidance is consistent with SEC and FASB releases to guarantee comparability across
borders.

The concept of fair-value measurement under SFAS 157 assumes orderly transactions
between market participants. The clarifications issued by the SEC and FASB did not suspend
fair-value accounting but rather seeked to provide companies and their accountants with
added flexibility in making fair-value determinations under present market conditions, in
which the sales of many exotic securities are effectively shut down. The clarifications focus
on inputs that may be used in applying various valuation techniques and provide that:

Strong judgement is required when determining fair value, and multiple inputs from different
sources may collectively provide the best evidence of fair value;

Management’s internal assumptions (expected cash flows, for example) may be used to
measure fair value when an active market for a security does not exist. In some cases, using
level 3 inputs may be more appropriate than using level 2 inputs, such as when significant
adjustments are required for available observable inputs;

Market quotes may be an input for the purpose of measuring the fair value of a security but
are not necessarily determinative if an active market does not exist for that security (however,
transactions in inactive markets may be inputs for the purpose of measuring fair value);

A significant increase in spread between the amount sellers are asking and the price that
buyers are bidding, or the presence of a relatively small number of bidding parities, is an
indicator that should be considered when determining whether a market is inactive;

The results of disorderly transactions, such as distressed or forced liquidation sales, are not
determinative; and

US GAAP does not provide a bright-line test in determining whether there is an asset
impairment that is not temporary (however, rules of thumb that consider the nature of the
underlying investment can be useful tools for management and auditors when identifying
securities that warrant a higher level of evaluation).

A non-comprehensive list of factors provided in the recent guidance to

determine whether a non-temporary asset impairment has occurred includes:

The length of the time and the extent to which the market value has been less than cost;

The financial condition and near-term prospects of the issuer, including any specific events
that may influence the operations of the issuer; and

The intent and ability of the holder to retain its investment in the issuer for a period of time
sufficient to allow for any anticipated recovery in market value.

ADDITIONAL DISCLOSURE

Because fair-value measurements and assessments of impairments may require strong

judgements, clear and transparent disclosures are critical to providing investors with an
understanding of the judgements made by management. For example, strong judgement must
be applied when using unobservable inputs to determine fair value, which may have a
material effect on the company’s results of operations, liquidity and capital resources. As
such, in addition to disclosures required under existing US GAAP, including SFAS 157, the
SEC’s Division of Corporate Finance recently issued letters in March and September 2008
that provided further guidance (disclosure guidance) regarding information that certain public
companies should consider in its Management’s Discussion and Analysis of Financial
Condition and Results of Operations disclosure contained in SEC filings. The disclosure
guidance suggestions include, among others:

If the use of unobservable inputs is material, disclosure of how such inputs were determined
and how the resulting fair value of assets and liabilities and possible changes to those values
affected or could affect the company’s results of operations, liquidity and capital resources;

A general description of the valuation techniques or models used about material assets and
liabilities, including describing the rationale and quantitative effect, to the extent possible, of
any material changes made during the reporting period to such techniques or models;

To the extent material, a discussion of the extent to which, and how, the company used or
considered relevant market indices in applying the techniques or models used to value
material assets or liabilities;

A discussion of how the company validates the techniques or models used; and

A discussion of how sensitive the fair value estimates for material assets or liabilities are to
the significant inputs for which the technique or model is used.

RECLASSIFICATION OF INVESTMENTS

Both IFRS and US GAAP require financial instruments to be classified into specific
categories at initial acquisition in a similar manner. US GAAP contains three broad
categories:

Trading;

Available-for-sale; and

Held-to-maturity.

IFRS contains four categories:

Financial assets at fair value through profit or loss (similar to trading under US GAAP);

Available-for-sale;

loans and receivables; and

Held-to-maturity.

The additional category under IFRS is not, in effect, significant. The key is that the
first two financial asset categories under both US GAAP and IFRS require the following of
mark-to-market accounting rules that have been the subject of write-downs during the credit
crisis.

Moreover, many financial institutions want to change their classification to held-to-

maturity, noting that their intention for these instruments has changed as a result of the
market turmoil. Generally, held-to-maturity assets are assets held with no intention to sell in
the short term or that are not otherwise part of a trading strategy. Such assets are measured on
a cost basis subject to impairment evaluation.

US GAAP permits reclassification of certain securities out of the trading category in

rare circumstances, which many are interpreting the present credit squeeze to represent,
whereas IFRS did not permit such reclassification. As a result, the IASB reacted swiftly to
issue a revision to IAS 39 to provide for a similar ability to reclassify financial instruments as
contained in US GAAP. This revision was immediately adopted by the EU. Reclassifications
under the revision can be made from 1 July 2008. Moreover, the press release issued by the
IASB stated that the deterioration of the world’s financial markets that has occurred during
the third quarter of 2008 is a possible example of a rare circumstance, thereby providing
financial institutions with an opportunity to reclassify their financial assets to held-to-
maturity, which exempts them from mark-to-market valuation and allows them to be valued
on a basis closer to their discounted cash flows.

It has been reported that Deutsche Bank was the first big EU financial institution to
implement this new rule, resulting in a profit instead of a projected loss in its most recent
third financial quarter by recategorising €24.9bn ($31.2bn) of loan exposure. In the third
quarter of 2008, it avoided €845m in write-downs because of the accounting change and was
able to report a net income of €414m instead of a €122m loss. Deutsche Bank shares rose 18
per cent to €20.20 in Frankfurt. Other financial institutions will also benefit from these
changes.

It is unlikely that mark-to-market will literally mean the same going forward. Recent
interpretation guidance by the SEC, FASB and IASB will lead more companies and their
accountants to attach less significance to market prices, particularly those in inactive markets,
when determining the value of securities, which in turn could support the assertion that write-
downs are not required in their individual cases. In addition, we expect the SEC to increase
scrutiny over disclosures made by reporting companies subject to material fair-value
accounting adjustments in their financial statements in light of the recent disclosure guidance.
Furthermore, the study of mark-to-market accounting recently conducted by the SEC will
likely change the mark-to-market rules and their application.

CASE STUDY

Two examples are given that show how financial assets and liabilities are disclosed, as
reported by HSBC Finance Corporation, which is incorporated in the US, and HSBC Bank
plc, a UK entity. Evidently, HSBC Finance Corporation categorized and reported the fair
values of its assets and liabilities based on the nature of valuation inputs (Note 15 to the
accounts). For example, the firm reported US$3,136 million of available for-sale securities,
of which US$354 million were fair value estimates from quoted prices in active markets
 (Level 1), US$2,743 million were fair value estimates from Level 2 inputs and US$39 million
originated from Level 3 valuation inputs.

In contrast, HSBC Bank plc has traditionally reported its fair values by measurement basis
(for example, £427,329 million as trading assets) in its Notes on the Financial Statements
(Note 15: Analysis of financial assets and liabilities by measurement basis). To provide
additional disclosures that are similar to SFAS 157’s disclosure requirements, HSBC Bank
plc disaggregated its £427,329 million of trading assets into fair value estimates that were
derived from quoted prices (£234,399 million), versus those fair value estimates that were
based on valuation methods using observable inputs (£185,369 million), and significant non-
observable inputs (£7,561 million).

REFERENCE

American Accounting Association Financial Accounting Standards Committee. 2000.

Response to the FASB Preliminary Views: Reporting Financial Instruments and Certain
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American Institute of Certified Public Accountants. 2001. Accounting by Certain
Entities(Including Entities with Trade Receivables) that Lend or Finance the Activities
ofOthers. Statement of Position 01-6. New York, NY: AICPA.

Bank of England. 2008. Financial Stability Report. Issue No. 23. April.

Barlevy, G. 2007. Economic Theory and Asset Bubbles. Economic Perspectives, Third
Quarter, 44-59.

Bies, S. 2008. Fair Value Accounting. Speech to the International Association of Credit
Portfolio Managers General Meeting, New York, New York, November 18.

CFA Institute. 2005. A Comprehensive Business Reporting Model: Financial Reporting for
Investors. Center for Financial Market Integrity. October.

Financial Accounting Standards Board (FASB). 1975. Accounting for Contingencies.
Statement of Financial Accounting Standards No. 5. Norwalk, CT: FASB.

_____. 1982. Accounting for Certain Mortgage Banking Activities. Statement of Financial
Accounting Standards No. 65. Norwalk, CT: FASB.

_____. 1991. Disclosures about Fair Value of Financial Instruments. Statement of Financial
Accounting Standards No. 107. Norwalk, CT: FASB.
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Financial Accounting Standards No. 115. Norwalk, CT: FASB.

_____. 1998. Accounting for Derivative Instruments and Hedging Activities. Statement of
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_____. 2000. Accounting for Transfers and Servicing of Financial Assets and
Extinguishments of Liabilities. Statement of Financial Accounting Standards No.140.
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_____. 2007. The Fair Value Option for Financial Assets and Financial Liabilities—
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Gron, A., and A. Winton. 2001. Risk Overhang and Market Behavior. The Journal of
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Johnson, S. 2008a. The fair-value blame game. 1www.cfo.com. March 19.

_____. 2008b. How far can fair value go? 1www.cfo.com. May 6.

Nissim, D. and S. Penman. 2008. Principles for the Application of Fair Value Accounting.
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Rummell, N. 2008. Fair-value rules get more blame for crunch. 1www.financialweek.com,
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Ryan, S. 2007. Financial Instruments and Institutions: Accounting and Disclosure Rules.
Hoboken, NJ: John Wiley & Sons.

Ryan, S. 2008. Accounting in and for the Subprime Crisis. The Accounting Review,
forthcoming. Senior Supervisors Group. 2008. Leading-Practice Disclosures for Selected
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United States Securities and Exchange Commission. 2005. Report and Recommendations
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Balance Sheet Implications, Special Purpose Entities, and Transparency of Filings by
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