Broderick Credits Mark to Market for Goldman Sachs Success

In his prepared statement to the Senate Permanent Subcommittee on Investigations, Chief Risk Officer of Goldman Sachs Craig Broderick explained how Goldman Sachs believes in a rigorous mark-to-market value assessment.
The central tenet is our daily discipline of marking all of the firm’s financial assets and liabilities to current market levels. We do so because we believe it is one of the most effective tools for assessing and managing risk, providing the most transparent and realistic insight into our risk positions and associated exposures. Goldman Sachs is one of the few financial institutions in the world that carries virtually all financial instruments held in its inventory at current market value, with any changes reflected immediately in our risk management systems.
Chief executive Lloyd C. Blankfein foreshadowed Broderick’s remarks in his own opening statement, “We believe that strong, conservative risk management is fundamental and helps define Goldman Sachs.”
During the contentious session, Mr Broderick credited Goldman’s risk management and mark-to-market accounting for minimizing its CDO losses in 2007-08.
This is an appropriate application of MTM. MTM for trading firms only. MTM disclosure for investors/banks/insurance. The accounting for investors should be different for traders and broker/dealers.

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Accounting Issues “Untouched” by Financial Regulatory Reform Bill

William Isaac, a former Federal Deposit Insurance Corp. chairman and now the chairman of LECG, expressed his objections to the Financial Regulatory Reform Bill now being debated in Congress.  He is quoted in American Banker as saying that, among other omissions, “What’s wrong with these bills is they do not fix the regulatory system that led us into this problem…They don’t deal with the accounting at all. Mark-to-market accounting was a major contributor to this crisis.”

Other critics argue that rules governing banks have actually been softened by the changes in mark-to-market accounting. Banks are now free to “write-up” the values of assets that had few, if any, buyers.

Mr. Issac also notes that the bill does not deal with the Basel capital accords and the procyclical accounting for loan-loss reserves. Nor does the bill institute an independent watchdog to oversee the system.

What’s the rush? Let’s do it right. The economy seems to be getting better. Let’s find a solution that works, rather than one that is easy to pass through Congress now…remember the old saying, “Decide in haste, repent at leisure.”

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Accountants, Washington Helping Banks Fluff Profits

Look for another rosy round of profits when banks turn in their numbers for the second quarter ending in June when it will be legal for them to improve their balance sheets by shifting losses into the future, thanks to new accounting rules passed by a one-vote margin by the Financial Accounting Standards Board (FASB).

It’s just one in a series of changes made to accounting rules that allow banks to shift or ignore losses or pretend that liabilities aren’t liabilities. The struggle for control of the financial recovery — where the money goes, how it’s counted and who survives — is nothing short of war. Truth has been the first casualty.

The latest rule change allows banks to split losses into ones that they recognize immediately and others that are pushed down the road and may pop up on the books later. It passed in April with barely any notice from the press. The accounting tricks allow banks, which may otherwise be deemed insolvent, to continue to operate. It’s a hell of a time to be an accountant.

Read more

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Financial Market Regulation – Rich Berg on CNBC Power Lunch

CNBC Power Lunch Market Task Force reactions to the House Financial Securities Committee hearing on Wednesday, March 25 and US government plans to implement additional market regulations. The Committee was inquiring about credit availability in the US banking system, and whether current regulatory or accounting structures were inhibiting lending.

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Congress Fuming after MTM Hearing

This article from CFO.com, Congress Members Fume at Fair Value, provides a clear summary of last week’s congressional hearing on fair-value accounting, emphasizing that Congressmen called for changes to mark-to-market rules, rather than an outright suspension of those rules. As most of us know by now, the meeting culminated in a promise from FASB to have some fair-value accounting rules guidance ready in three weeks. However, only time will tell whether this guidance will actually solve the issue or not. In the meantime, Representative Alan Grayson (D-FL) and FASB Chairman Robert Herz both believe that some institutions are waiting to write down damaging assets until potentially beneficial rule changes are enacted.

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More MTM Pain

This WSJ article on the FHLB provides a solid real-world example of how mark-to-market accounting has drastically affected banks. In the fourth quarter, the FHLB recorded a combined loss of $672 million-their first loss in about 20 years. This loss resulted from massive write-downs on mortgage securities that some home-loan banks had picked up in recent years in hopes of attaining higher yields.

Further obstacles may await home-loan banks with regards to their main business, which is making loans, or advances, to the commercial banks, credit unions, insurers, and thrifts that make up the home-loan banks’ membership. Banks’ demand for advances has gone down after receiving direct financial aid from the government, and this demand may decrease still further if the FDIC enacts a planned rule change that would require institutions with high dependence on advances to pay higher fees. Considering these complications, it seems further challenges are in store for home-loan banks.

Read this article that was in the WSJ yesterday:  Mortagage Securities Drag FHLB to a Loss.

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McTeer testimony to the Financial Services Subcommittee

Former Dallas Fed Governor Robert McTeer’s testimony to the Financial Services Subcommittee on mark-to-market accounting:

MARK-TO-MARKET ACCOUNTING:  Practices and Implications

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Today’s FAS Hearing – LIVE

Handout:    http://www.fasb.org/board_handouts/03-16-09.pdf

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5 Step Recovery Plan for America

The views expressed in this commentary are solely those of Richard S. Berg.

Step #1:  Restore confidence in housing market.

Solution:  Offer price protection for 5 years to any new purchase of a home for owner occupied purchasers.

Rationale:  People who are interested in purchasing a home are still aware that the market has not bottomed, and they may become upside down.  If the U.S. Government offers “price insurance” of 95% of the purchase price for 5 years in exchange for a monthly insurance premium added to the mortgage, that risk has been eliminated for the homebuyer.  The government is currently insuring virtually every mortgage loan written today to the lender; why not to the borrower?  Hyundai has established a similar program for new car sales, and it has been extremely successful.  This would be revenue positive for the U.S. Government.

Step # 2:  Increase spendable cash flow for every homeowner by almost $3,000 per year

Solution:  The US Government should offer a 4.50% fixed rate 30 year refinance to every mortgage borrower regardless of loan size and appraised value.

Rationale:  Assuming an outstanding mortgage amount of $250,000 at a 6.5% interest rate, the annual savings by refinancing that loan into a 4.5% rate would be $3,768 per year.  That extra cash would certainly work its way into the economy!  The only criteria is that you have to be current on your payments for the past 12 months in your previous mortgage.  This would be revenue neutral to positive for the US Government because they can currently borrow for 30 years below 4%.  Freddie and Fannie Mae can sell these refinanced loans as government guaranteed mortgaged back securities.  Freddie and Fannie Mae already have most of this exposure;  let’s use their mandate to help current homeowners.

Step #3:  Eliminate 50% of the “toxic” assets, increase the valuation of the remaining ones and recapitalize the banking system

Solution:  See #1 & 2

Rationale:  Since the majority of the “toxic” assets are mortgage related, and because the majority of mortgages have been securitized, solutions like the TARP and mortgage remediation have fallen short.  What you may not know is that a minority of “bad loans” inside a security can cause the entire security to be viewed as “toxic”.  Refinancing the good loans will significantly reduce the amount of outstanding “toxic” securities, and also allow banks to “write up” many of their previous “write downs”.  Hundreds of billions of capital and market value would be restored to the financial system without direct government intervention.

Step #4:  Heal the banks and restore lending in America

Solution:  Pass a 3 year reduction in capital requirements in banks, reduce rather than increase the regulatory scrutiny, and redefine “Fair Value” for OTTI to the “expected loss incurred.”

Rationale:  Banks are not lending because they are preoccupied with self-preservation.  Banks must keep a minimum level of capital or they will be deemed insolvent and closed.  Write downs of “anticipated” losses in advance of the realized losses can be very tricky, especially in this market.  Many of today’s write downs will not ultimately result in anywhere as severe as realized loss.  Regulation and accounting both contribute to this downward spiral of capital (as well as falling asset values, which #1 will certainly positively impact).  Regulators are under intense pressure to “regulate” better, which has an adverse reaction, banks refuse to lend out of regulatory and accounting fears.  If we enact numbers 1, 2, and 3, banks will actually become much healthier over a reasonably short time frame period because many of their “write downs” will be certainly not be realized.

Step #5:  Stop draining capital from the system that requires more bailouts

Solution:  Enact a “mark to market” holiday for 3 years.

Rationale:  Did AIG really lose $60 billion dollars?  For reported earnings and capital levels the answer is yes, although much of that write down and others’ write downs reflect very long term commitments that may actually turn out to produce vastly different cash flow results.  Unfortunately, in a regulated business such as banking and insurance, once your reported capital levels are below minimum, you are effectively out of business unless “bailed out.”  MTM caused wildly inflated asset prices on the way up during the boom. Can we at least agree that the current MTM accounting rules are causing wildly negative unintended consequences, and if not halted may ultimately put every financial institution and insurance company out of business?  There is a better solution and let’s take 3 years to study what it should be before we cause additional damage.

Interestingly, the implementation of this 5 step program would likely not cost the US taxpayer a dime, but we believe the impact to the US and world markets and economy would be profound.

Copyright 2009. Richard S. Berg. All rights reserved.

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Plea to Chairman Frank

A Congressional subcommittee hearing on mark-to-market accounting is due to take place on Thursday. To that end, on Monday, ABA, in a joint effort with 18 trade groups and all of the Federal Home Loan Banks, sent this letter to the House Financial Services Committee that articulated their desire that the aforementioned hearing prompts immediate action to correct mark-to-market accounting rules so that the losses they have brought about do not continue. The letter further emphasized the urgency that this issue demands with regards to enacting changes, due to the fact that these capital losses are quickly and unnecessarily destroying banks.

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