Fair value - Bring back Prudence

We should eschew monopoly in accounting and allow alternative sets of standards to compete, argue Stella Fearnley and Shyam Sunder.

Fairness is a judgment, not a description; in our discussion of valuation in financial reporting we set aside the rhetorically loaded 'fair' value in favour of the neutral 'current' value. The 'fair' label discourages discourse by implying that its critics favour 'unfair' accounting.

Discussions of fair value accounting have focused on two issues: the decision usefulness and stewardship functions of accounting. We discuss both and show that current valuation is no better than other valuation methods in serving either of these two goals; in some respects it is worse. It may also undermine the reliability of the audit opinion.

The usefulness of current values for making investment decisions is a simple and straightforward statistical argument: if a company's resources are valued more accurately, decisions based on more accurate data would be better. Since value of resources tends to change over time, historical numbers associated with resource acquisition transactions tend to become obsolete with the passage of time, thus creating price movement inaccuracies. Other things being equal, current values should provide more accurate data and therefore be a better basis for making investment decisions.

Other things are not equal

However, other things are not equal. Current values of some resources can be determined with precision, especially if they are standardised, and traded in liquid markets. Steel girders, food grains, automobiles and treasury bonds are examples of such resources. Financial reports based on current prices of such liquid resources (adjusted for their small transaction costs) serve the decision-making function well. The case for current value accounting is based on such resources.

If all resources belonged to this 'liquid' class, the decision-usefulness argument for current values would be quite reasonable. Unfortunately, this is not so in most companies, industries, or the economy as a whole. Most resources are not so liquid, and their current values are subject to estimation or guesswork that introduces varying degrees of inaccuracy in the current numbers, thus creating price measurement errors.

Whether current values are more useful for making decisions depends on the relative magnitudes of the two kinds of errors: movement errors arising from ignoring the changing prices; and measurement errors arising from the imperfections in the markets from which current values are determined. Price instability (for example, inflation, demand or technological change) contributes to movement errors while market imperfections contribute to measurement errors.

When movement errors are large relative to measurement errors, current values are better for decision-making; when the reverse is true, the use of current values results in worse decisions.

Price volatility, and therefore the magnitude of movement error, varies by resource, company, industry, economy and over time. Similarly, market imperfections, and therefore the magnitude of measurement error, also vary by resource, industry and economy. Whether current valuation yields a better basis for making decisions would depend on the specific circumstance; it is not possible to establish their general superiority or inferiority for this purpose. Yet, the standard-setters have chosen to make current values the new basis of accounting for all resources, companies and industries, ignoring the absence of logical or evidentiary basis for its superiority for making decisions.

Stewardship problem

Besides the statistical problem of identifying the circumstances in which current values do and do not serve as a basis for making better investment decisions, there is a stewardship problem.

Shareholders entrust managers with their investment in companies to be run for their mutual benefit. They expect a higher rate of return for themselves by rewarding managers efficiently to deploy their skills in conjunction with capital. What kind of financial reporting arrangement between the owner and manager better serves the interests of both?

When the shareholder cannot know whether or not the financial reports from the managers are factually correct, the possibility of manipulation by the managers of inaccurate valuations made in good faith, reduces the confidence of the shareholder in both the financial reports and in the managers. Absence of trust leads to precautionary moves, which render the relationship less productive to both.

Undermining the audit

Given the measurement errors associated with current values of most resources, their blanket use in financial reporting is a prescription for poorer stewardship and accountability of managers. It may also undermine the value of audit, a key function in reinforcing capital markets' confidence in financial reporting.

The International Accounting Standards Board and the US Financial Accounting Standards Board's proposed conceptual framework for financial reporting is a model of relevance, faithful representation, neutrality, completeness and comparability. It has moved away from reliability and conservatism. Substance over form is subordinated to faithful representation.

When a market mis-prices securities, such as during the dot.com boom and the subprime mortgage market, accounting reports based on current values reflect inflated prices and tend to support, or even reinforce price bubbles.

Audit is an important subset of financial reporting and depends heavily on the quality of the reporting standards. Going forward, auditors may report that current value financial statements are in compliance with GAAP under its conceptual framework. If there are publicly available market prices, the auditor may verify that current values faithfully represent market values but that value may not be neutral or comparable with others. Absent availability of prices from liquid markets, the auditor becomes more dependent on managers' judgment and assurances about the values of some assets. Auditors may find themselves having to express an opinion on a mark to model estimate, which US pundit Warren Buffett has suggested may become mark to myth.

Because current value information may lack reliability, the level of assurance an auditor can offer on current value financial statements will be lower and the value of the audit to shareholders may be diminished.

Under a stewardship regime as in the UK, shareholders may well prefer an audit carried out under a true and conservative accounting model that gives primacy to substance over form and provides the opportunity to apply judgment to override distortion.

If the subprime bubble does nothing else, it questions whether accounting should simply reflect bubbles or should help bring restraint into financial reporting. Without truth, fairness and conservatism, it will be more difficult for shareholders to assess the stewardship of managers. It is still not clear whether, under the 2006 Companies Act, true and fair will return as it was before International Financial Reporting Standards or will remain subordinated to it.

How does a current value balance sheet, when some such values cannot properly be substantiated, contribute to adequate assessment of future cashflows for decision- making? We should invite our old friend Prudence back to financial reporting and auditing. We miss her, and under fair value accounting, so will the auditors.

False prophets

We have consistently maintained that there is no one answer to the world's accounting dilemmas. All accounting is defective and will continue to be defective as long as business activities and behaviours continue to change. Standard-setters may believe that they have found the holy grail. However, like The Da Vinci Code, the proposed answer remains unconvincing. We should eschew monopoly in accounting and allow alternative sets of standards to compete to attract a following in the marketplace rather than persist with a model that supports false prophets.

Stella Fearnley is professor of accounting at Bournemouth University. Shyam Sunder is James L Frank professor of accounting, economics and finance at Yale School of Management.

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