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	<title>Comments on: Mark To No Market Accounting</title>
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	<description>Clarity In A World Of Obfuscation</description>
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		<title>By: JKH</title>
		<link>http://derivativedribble.wordpress.com/2008/11/17/mark-to-no-market-accounting/#comment-166</link>
		<dc:creator>JKH</dc:creator>
		<pubDate>Tue, 18 Nov 2008 15:57:40 +0000</pubDate>
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		<description>Proponents of marked to market accounting usually insist it’s a necessary thing for transparency. But the necessary condition is really disclosure of marked to market value rather than accounting for it. It’s quite possible for a firm to release all matter of marked to market information without necessarily jamming the spuriously precise result into its capital position every 90 days.</description>
		<content:encoded><![CDATA[<p>Proponents of marked to market accounting usually insist it’s a necessary thing for transparency. But the necessary condition is really disclosure of marked to market value rather than accounting for it. It’s quite possible for a firm to release all matter of marked to market information without necessarily jamming the spuriously precise result into its capital position every 90 days.</p>
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		<title>By: Humean, All Too Humean</title>
		<link>http://derivativedribble.wordpress.com/2008/11/17/mark-to-no-market-accounting/#comment-165</link>
		<dc:creator>Humean, All Too Humean</dc:creator>
		<pubDate>Tue, 18 Nov 2008 15:07:45 +0000</pubDate>
		<guid isPermaLink="false">http://derivativedribble.wordpress.com/?p=1071#comment-165</guid>
		<description>Point: &quot;Suspending mark-to-market accounting, in essence, suspends reality.&quot; - Beth Brooks, global chair Ernst &amp; Young 

Counter-Point: If there is no market, or no efficient/liquid/... market, mark-to-market becomes Slumlord&#039;s &quot;mark to myth&quot; at best.  At worst, otherwise healthy institutions may face huge paper losses with attendant ill effects.  The fact that firesale prices have persisted so long may reflect the assets&#039; true value, but it may just be a product of frightened and cash-starved market players&#039; uncertainty in the post-MBS-meltdown wasteland.

Conversely, in a bubble market, mark-to-market creates ephemeral paper gains that encourage investments in companies with tulips on their balance sheets.

Mark-to-market may be better or worse than its predecessors, but it&#039;s certainly not perfect.</description>
		<content:encoded><![CDATA[<p>Point: &#8220;Suspending mark-to-market accounting, in essence, suspends reality.&#8221; &#8211; Beth Brooks, global chair Ernst &amp; Young </p>
<p>Counter-Point: If there is no market, or no efficient/liquid/&#8230; market, mark-to-market becomes Slumlord&#8217;s &#8220;mark to myth&#8221; at best.  At worst, otherwise healthy institutions may face huge paper losses with attendant ill effects.  The fact that firesale prices have persisted so long may reflect the assets&#8217; true value, but it may just be a product of frightened and cash-starved market players&#8217; uncertainty in the post-MBS-meltdown wasteland.</p>
<p>Conversely, in a bubble market, mark-to-market creates ephemeral paper gains that encourage investments in companies with tulips on their balance sheets.</p>
<p>Mark-to-market may be better or worse than its predecessors, but it&#8217;s certainly not perfect.</p>
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		<title>By: Catfish</title>
		<link>http://derivativedribble.wordpress.com/2008/11/17/mark-to-no-market-accounting/#comment-164</link>
		<dc:creator>Catfish</dc:creator>
		<pubDate>Tue, 18 Nov 2008 14:18:52 +0000</pubDate>
		<guid isPermaLink="false">http://derivativedribble.wordpress.com/?p=1071#comment-164</guid>
		<description>This is something with which I have some experience and have written about.  My interest is specifically for environmental liabilities, not for financial instruments.

The central issue is how to manage the reality of the variance of asset and liability valuations in real time (annual and quarterly reports).  While the propose fair value measurement methods specified in FAS-157 have led to significant problems for some financial companies, the reality is that the assets on their balance sheets has dropped precipitously.  As Al Gore would say, that is an inconveient truth.  This is no different than people who are looking at &quot;paper losses&quot; in their IRA of 40-50%.  That is the reality.  If that person is say 40, he can argue that 25 years from now this current dip is of no consequence.  If that person is 70, he has some real issues.  Regardless, the drop is what it is.

Another objection I hear from accountants is that FVM creates too much &quot;paper&quot; fluctiuations in assets and liabilities which extend over to the income statement.  That is another story for another day.  One which seems as though it can be addressed through FASB amendments.  

But mostly, there seems to be an inherent discomfort with the concept of fixed asset valuations fluctuating.  In my experience, accountants are simply loathe to live in a world where fixed asset valuations flucuate because fixed assets are supposed to be, well ... fixed. 

As something of an outsider, my impression is that, among other things, FVM bring to light the uncertainty in asset and liability valuations.  And by extention, the uncertainty can create risk.  I submit that FVM should be used to identify uncertainty and risk, and had it been properly employed earlier in this cycle, maybe corrective action would have been taken bginning in 2006 or maybe even 2005.

Banks and insurance companies should have known and should have reported that the risky positions they were taking might lead to a future need for extensive capitalization.  If they did not possess the wherewithal for this possible outcome, they should not have taken on the risk.  It seems to me that the original sin of FAS-157 is that it compels corporate officers to see the truth and to tell the truth.  I, for one, can live with that.</description>
		<content:encoded><![CDATA[<p>This is something with which I have some experience and have written about.  My interest is specifically for environmental liabilities, not for financial instruments.</p>
<p>The central issue is how to manage the reality of the variance of asset and liability valuations in real time (annual and quarterly reports).  While the propose fair value measurement methods specified in FAS-157 have led to significant problems for some financial companies, the reality is that the assets on their balance sheets has dropped precipitously.  As Al Gore would say, that is an inconveient truth.  This is no different than people who are looking at &#8220;paper losses&#8221; in their IRA of 40-50%.  That is the reality.  If that person is say 40, he can argue that 25 years from now this current dip is of no consequence.  If that person is 70, he has some real issues.  Regardless, the drop is what it is.</p>
<p>Another objection I hear from accountants is that FVM creates too much &#8220;paper&#8221; fluctiuations in assets and liabilities which extend over to the income statement.  That is another story for another day.  One which seems as though it can be addressed through FASB amendments.  </p>
<p>But mostly, there seems to be an inherent discomfort with the concept of fixed asset valuations fluctuating.  In my experience, accountants are simply loathe to live in a world where fixed asset valuations flucuate because fixed assets are supposed to be, well &#8230; fixed. </p>
<p>As something of an outsider, my impression is that, among other things, FVM bring to light the uncertainty in asset and liability valuations.  And by extention, the uncertainty can create risk.  I submit that FVM should be used to identify uncertainty and risk, and had it been properly employed earlier in this cycle, maybe corrective action would have been taken bginning in 2006 or maybe even 2005.</p>
<p>Banks and insurance companies should have known and should have reported that the risky positions they were taking might lead to a future need for extensive capitalization.  If they did not possess the wherewithal for this possible outcome, they should not have taken on the risk.  It seems to me that the original sin of FAS-157 is that it compels corporate officers to see the truth and to tell the truth.  I, for one, can live with that.</p>
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		<title>By: Slumlord</title>
		<link>http://derivativedribble.wordpress.com/2008/11/17/mark-to-no-market-accounting/#comment-163</link>
		<dc:creator>Slumlord</dc:creator>
		<pubDate>Tue, 18 Nov 2008 12:49:15 +0000</pubDate>
		<guid isPermaLink="false">http://derivativedribble.wordpress.com/?p=1071#comment-163</guid>
		<description>Mark to market is what you will get for an asset. Mark to model, myth, dream etc is what you &lt;i&gt;might&lt;/i&gt; get. Mark to myth accounting involves more uncertainty and hence risk than mark to market. Mark to market has its flaws but it is the least risky way to evaluate the price of assets.

The problem with mark to market is however, when market conditions are &quot;irrational&quot; but irrational is usually measured from the point of view of the asset holder. The &quot;firesale&quot; that the banks are complaining about, has been going on for close to 18 months now. The market is probably accurately pricing these assets.</description>
		<content:encoded><![CDATA[<p>Mark to market is what you will get for an asset. Mark to model, myth, dream etc is what you <i>might</i> get. Mark to myth accounting involves more uncertainty and hence risk than mark to market. Mark to market has its flaws but it is the least risky way to evaluate the price of assets.</p>
<p>The problem with mark to market is however, when market conditions are &#8220;irrational&#8221; but irrational is usually measured from the point of view of the asset holder. The &#8220;firesale&#8221; that the banks are complaining about, has been going on for close to 18 months now. The market is probably accurately pricing these assets.</p>
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