would be difficult to obtain a market value. However, it seems fairly easy to impute a market
value for financial assets and liabilities, so this argument does not seem particularly relevant
except perhaps for very small institutions.
2. Managers do not want unrealized (paper) gains and losses to be reflected in income, claiming
this would excessively destabilize earnings and equity. Accounting theory tells us that the
purpose of income as it is measured is to smooth out fluctuations in cash flows through time
to provide a better picture of value than short term, highly variable cash flows. Accruals
adjustments supposedly give a truer picture of the cash flow potential of the firm over the
long term. Stock prices appear to more closely follow income than short term cash flows or
EVA adjusted cash flow measures. Managers claim they hold many of their assets and
liabilities to maturity and marking them to market would simply distort the value of the bank
to shareholders. Moreover, the FDIC claims that marking to market could cause them to
have to close an institution that might otherwise survive simply because of a short term
interest rate movement. Both arguments have some validity but are incorrect theoretically.
The managers’ claim that we should not update values as market conditions change implies
that equity should measure something other than present value of expected future cash
flows.4 An economic variable that measures future prospects must be unstable if those
prospects are changing. Bankers and accountants don’t think this way though. They want a
measure of value that is stable and encourages accountability. The FDIC’s argument forgets
that during the 1980s the FSLIC went bankrupt (and the FDIC came close) because book
value accounting allowed institutions to build large losses which the insurer eventually had to
pay. There is also an implicit assumption in their argument that an interest rate change will
be reversed in time to restore profitability to the institution. I doubt the validity of that
argument, but more importantly, I would counter that if a short term interest rate move can
put an institution under then the regulators need to bring about a change in management at
that institution anyway.
3. FIs also maintain that they would be less likely to engage in long term lending and investing
if these accounts were regularly marked to market. This statement itself is very revealing as it
indicates that FI managers recognize that the current accounting rules allow managers to
take on more risk than they could otherwise. There might be disruptions in the short run,
but in a free capital system, other new lenders would emerge if banks refused to make these
loans. They may not make as many, or they may increase the price of the loans, or they may
simply hedge more. This appears to be a disingenuous argument.
4. The industry argues the lack of liquidity in the recent crisis led to unrealistically low market
values of assets and marking to market imposed excessive losses on institutions.
Consequently the Financial Accounting Standards Board (FASB) allows management to rely
on internal estimates of cash flows to estimate fair value. This is referred to as ‘marking to
model’ rather than ‘marking to market.’ This makes sense in a non-functioning market
environment but it still allows FIs to not update the value of assets and liabilities to current
market conditions and adds subjectivity that is likely to be manipulated by management.
4 Alternatively managers may be implicitly implying that the maturity of their investments is the
proper time horizon over which value should be measured, but equity does not mature when their
investments do so they are ignoring reinvestment risk over the longer time horizon, the value of
which is better captured by current market values.