Vodafone attacks ‚Äòcostly and burdensome’ code change – Accountancy Age.

Good news and common sense:

The UK’s biggest companies have attacked proposed changes to the UK accounting code as potentially costly, pointless and painstaking for large business.

The companies have together urged the Account ing Standards Board (ASB) to rethink plans to replace the current UK accounting rule book, known as UK GAAP, in favour of new international standards for small and medium-sized businesses (SMEs).

Their voices joined Shell, Hilton Hotels and Vodafone in opposition to elements of the ASB’s proposals.

Their concerns focus on whether the rules may affect the thousands of listed subsidiaries of UK companies.

Fair value accounting for SMEs makes about as much sense as supplying water in leaking buckets.

Big business has done small business a favour here.

Next the IASB needs to adopt an appropriate conceptual framework for big business….

 

I’m told one member of the audience at yesterday’s meeting where Adair Turner spoke about the need to transform the accounting of banks asked:

whether a failed standard setter should be able to fail, given free market principles..?

A panellist from the right wing American Enterprise Institute said "good question" and:

it hasn’t failed financially but it has failed intellectually, so it should be allowed to fail.

and added:

It shows the problem of one uniform model when it is the wrong one

which rather reminds me of Voltaire who said:

It is dangerous to be right in matters where established men are wrong.

Not spoken in jest, I suspect.

 

Earlier this week I had an article on Forbes about the absurdity of bad debt less provisioning for banks under the rules of International Financial Reporting Standards established by the International Accounting Standards Board. I summarised all the arguments there: I won’t repeat them.

Yesterday Adair Tuner – Lord Turner, chair of the Financial services Authority – joined in the attack in a speech at the Institute of Chartered Accountants in England and Wales. The speech is here. It is, I admit, pretty technical. It’s also (rather refreshingly) highly competent. he asked the question:

So are banks different in ways relevant to accounting standards? In what ways, and what should we do about it?

His answer was they are, of course. As he noted:

Two aspects of bank accounting in particular could be relevant to the macro-prudential and macroeconomic concerns which make banks different.

  • First, the treatment of loan losses within the banking book, the way in which we capture, or fail to capture, present or future potential loan losses arising from credit default.
  • Second, the valuation approach in the trading book (and other items which are marked to market), the recognition of unrealised gains or losses in general, but in particular in more illiquid securities.

In both these areas, there is a strong case that the present accounting treatment contributes to the problem of procyclicality.

To out it another way, mark to market accounting rules when used by banks helped create the current crisis for the reasons I noted in Forbes. Or as he puts it:

On the banking book side, the current IASB accounting treatment requires banks to recognise the implications for potential loan losses of events which have already occurred, such as failures to make interest or principal payments; but also requires them only to recognise such known events, not to anticipate possible or probable future events. This necessarily implies that loan loss provisions will vary dramatically through the economic cycle, and means that in good years income will be declared which does not reflect the average future loan losses likely to arise from loans being put on the books.

As a result, this accounting treatment can contribute to a cycle of self-reinforcing responses which tends to exacerbate the volatility of credit extension and of the economic cycle, both on the way up and the way down.

At long last! Someone has said it. Actually, he said more than that. As he pointed out:

For the fundamental problem we face is that there are no definitive ‚Äòfacts’ about value – but that value in financial markets is contingent on specific circumstances and on the action of all other participants. For an individual bank selling slices of its individual portfolio in conditions where the actions of other banks can be considered as independent, mark-to-market accounting provides meaningful facts and a useful management discipline. But if all banks simultaneously try to sell all or a significant proportion of their assets, the facts become quite different.

Or to put it another way – those who built accounting rules on the basis of the efficient market hypothesis get those rules very, very wrong.

So he argues for a new form of accounting for bank losses:

Faced with that trade off between divergent aims, the FSA’s ideal preference would be to provide not one but two separate lines of account information on loan loss provisions.

  • The existing line, based as now, on the facts of already incurred credit impairment events.
  • And a separate line, based either on a formula, as in Spain, or on the judgements of management, challenged by regulators, and with the details, basis and rationale for that judgement extensively disclosed.

Which is am pretty damning indictment of what has gone before.

It’s also a damning indictment of the International Accounting Standards Board’s claim that the only people with interest in accounts are providers of capital. he is saying there is reason to provide data for many more reasons than that, and if that is all that is done disaster can follow – as it has.

Not a good day for the IASB. Or banks

But a good day for accountancy, maybe.

 

IFRS 8, ‚ÄòOperating Segments’ has been applied to some 2008 financial statements of quoted companies and to all their 2009 interim statements.

The standard has been controversial since its adoption was proposed. This is not, unlike other International Financial Reporting Standards a truly European standard. IFRS 8 was lifted straight from US GAAP as a political gesture to the US Federal Accounting Standards Board to show the process of alignment of standards would not mean US GHAAP would be completely subsumed by the IFRS.

The difficulty was that academic research had already shown that the US equivalent of IFRS 8 (called SFAS 131) had been bad news for shareholders. 

So it looks like it is also proving to be now the standard has been put into use in Europe. In its pronouncement of 2010 the Financial Reporting Review Panel of the Financial Reporting Council has said it is concerned about how companies are reporting the performance of key parts of their business in the light of the introduction of IFRS 8. It requires some understanding of IFRS 8 and its predecessor, International Accounting Standard 14, to see why.

IFRS 8 requires companies to provide an analysis of profit, assets and liabilities so that investors can see the performance of the principal operations or "segments" of the reporting entity. The new standard requires management to define the company’s operating segments in accordance with how its operations are managed in practice. In this way the IASB sought to respond to criticisms of IAS 14 (the previous standard), to reduce the ability of management to disguise poor performance of a part of the business, and to enable investors to review a company’s operations from the same perspective as management. IAS 14 supposedly did this by focussing primarily on the disclosure of segment data by geographic location (usually by continent) with business focussed data being treated as secondary.

However, in doing so IAS 14 had some considerable advantages over IFRS 8:

¬? All trade had to be allocated to a segment so that segment reports had to reconcile to the full financial statements. This is not required under IFRS 8 where only 75% of trading need be segment reported;

¬? The same accounting standards had to be used for IAS 14 segment reports as for the main financial statements. This would seem logical. It is not a requirement of IFRS 8 – so its segment data can offer a completely different view from the rest of the audited financial statements.

¬? ISA 14 segments were to an extent mandatory assisting comparison between entities and over time. IFRS 8 segments are created by the company at will. There is no reason why they need ever be consistent.

The resulting problems are already coming to light. The FRRP has apparently reviewed a sample of 2009 interim accounts and 2008 annual accounts (when they had early applied the standard) and has asked a number of questions about the implementation of IFRS 8. In particular they have asked a number of companies to provide additional explanations where:

  • only one operating segment is reported, but the group appears to be diverse with different businesses or with significant operations in different countries;
  • the operating analysis set out in the narrative report differs from the operating segments in the financial statements;
  • the titles and responsibilities of the directors or executive management team imply an organisational structure which is not reflected in the operating segments; or
  • the commentary in the narrative report focuses on non-IFRS measures whereas the segmental disclosures are based on IFRS amounts.

The FRRP has encouraged Boards of Directors to test their initial conclusions about their segmental reporting by considering the following questions:

  1. What are the key operating decisions made in running the business?
  2. Who makes these key operating decisions?
  3. Who are the segment managers (as defined in the standard) and who do they report to?
  4. How are the group’s activities reported in the information used by management to review performance and make resource allocation decisions between segments?
  5. Is any proposed aggregation of operating segments into one reportable segment supported by the aggregation criteria in the standard, including consistency with the core principle?
  6. Is the information about reportable segments based on IFRS measures or on an alternative basis?
  7. Have the reported segment amounts been reconciled to the IFRS aggregate amounts?
  8. Do the accounts describe the factors used to identify the reportable segments including the basis on which the company is organised?

As a final question, the FRRP has reminded management to ask themselves whether the reported segments appear consistent with their internal reporting and, if not, why not.

The nature of these questions is pretty damning. It suggests that at least in some cases the FRRP believes management is misleading shareholders.

Those, like me, who criticised the adoption of IFRS 8 from the outset predicted this would happen: the US research, which I have summarised  here showed that managers, when not monitored by shareholders, will make self-maximizing decisions which may not be in the best interest of those shareholders. These decisions include aggressively growing the firm, which reduces profitability and destroys firm value. They used geographic earnings disclosures to examine this issue. Statement of Financial Accounting Standards No. 131 (SFAS 131), which is almost identical to the controversial new IASB standard IFRS 8 let them do so. Under its provisions US companies could abandon geographic disclosure of earnings and other key data. They expected that such non-disclosure potentially reduced the ability of shareholders to monitor managers’ decisions related to foreign operations.

Using a sample of U.S. multinationals with substantial foreign operations, they found that geographic non-disclosing firms experienced greater expansion of foreign sales, produced lower foreign profit margins and had lower firm value in the post-SFAS 131 period when compared to companies that continued to disclose geographic earnings. These differences did not exist in the pre-SFAS 131 period and did not relate to domestic operations. Compellingly, the only variable they could find that explained this was disclosure of geographic data.

In other words, IFRS 8 and its US equivalent are bad for shareholders because directors wilfully mislead them whilst pursuing their own aggressive agendas in vain pursuit of self –glorification.

There is an alternative: for some years I have been promoting the idea of country-by-country reporting. This version of segment reporting would require disclosure of the following information by each Multinational Corporation (MNC) in its annual financial statements:

1. The name of each country in which it operates;

2. The names of all its companies trading in each country in which it operates;

3. What its financial performance is in every country in which it operates, without exception, including:

¬? It sales, both third party and with other group companies;

¬? Purchases, split between third parties and intra-group transactions;

¬? Labour costs and employee numbers;

¬? Financing costs split between those paid to third parties and to other group members;

¬? Its pre-tax profit;

4. The tax charge included in its accounts for the country in question split as noted in more detail below;

5. Details of the cost and net book value of its physical fixed assets located in each country;

6. Details of its gross and net assets in total for each country in which operates.

Tax information would need to be analysed by country in more depth requiring disclosure of the following for each country in which the corporation operates:

1. The tax charge for the year split between current and deferred tax;

2. The actual tax payments made to the government of the country in the period;

3. The liabilities (and assets, if relevant) owing for tax and equivalent charges at the beginning and end of each accounting period;

4. Deferred taxation liabilities for the country at the start and close of each accounting period.

This is real segment reporting, disclosing who does what, where and with what attached risk. The added value is enormous and for the first time people would be able to meaningfully assess the risk they engage in when trading with a multinational corporation. In addition, the whole issue relating to transfer pricing abuse would be exposed.

It’s for the last reason that many of the world’s most significant development charities support country-by-country reporting and the OECD is now looking at the issue, which already has the support of the EU Parliament.

As IFRS 8 fails to deliver the demand for country-by-country reporting can only grow.

 

The FT notes:

Europe should not have handed over control of accounting rules to the London-based International Accounting Standards Board, according to the chief executive of Axa, France’s largest insurer.

Henri de Castries lambasted the IASB as being “accountable to no one”, saying the setting of accounting norms was “an instrument of political sovereignty” and “far too important to leave to accountants”.

The comments come as the standard-setter is re-working the rules covering financial reporting in the wake of the global crisis.

He’s right. It is staggering that we have allowed a company basically controlled by the Big 4 firms of accountants take over the rules of law making on accounting reporting in the UK, the whole of Europe and beyond.

Especially when, as the G20 has noted, they ignore their stakeholders, as they have on country-by-country reporting.

 

The G20 communiqu?© says:

We call on our international accounting bodies to redouble their efforts to achieve a single set of high quality, global accounting standards within the context of their independent standard setting process, and complete their convergence project by June 2011. The International Accounting Standards Board’s (IASB) institutional framework should further enhance the involvement of various stakeholders.

The International Accounting Standards Board has a long way to go. Their record with civil society on IFRS 8 is dire. Their refusal to recognise anyone but a provider of capital as a user of accounts is a flagrant breach of their public duty.

Memo to the G20, from civil society: bring them into line.

 

Accounting Standards given tongue-in-cheek reform award .

The International Accounting Standards Board (IASB) has been handed a tongue-in-cheek award from Christian Aid, after winning the charity’s Greatest Potential for Tax Reform award.

The Board was handed the Golden Palm this morning (10 September) at its headquarters in Cannon Street by aid activists

Activists want the Board, which is responsible for drawing up rules covering how companies draw up their annual accounts, to instigate urgent and far-reaching reforms – including forcing companies trading internationally to report profits made and taxes paid in every country where they operate

Christian Aid estimates that countries in the developing world are deprived of $160 billion annually in lost revenues by companies disguising their tax liabilities.

If used according to current spending patterns, the money could save the lives of 350,000 children under the age of five every year, the group argues.

PriceWaterhouse Coopers (PwC), KPMG, Ernst & Young and Deloitte & Touche also collected awards, along with the Board.

At the time of writing, none of the ‘big four’ financial services companies other than PwC replied on the record to politics.co.uk’s requests for a comment.

But Barry Marshall, PwC’s UK head of tax said: “PwC has met with Christian Aid to discuss our shared interest in improving corporate reporting of tax information and indeed subsequently continued this dialogue in writing. We have a common interest to continue to improve corporate reporting of tax information.

“PwC has led the profession in promoting more transparency in tax and wider corporate reporting. We reiterate our willingness to discuss these important matters with Christian Aid and other interested parties.”

Sep 092009
 

I contributed to a programme broadcast in two parts on the BBC over the last week or so on the profits made by mainstream companies from hard core pornography. The download is still available here.

Why do this? First, the reporter seemed genuine. Second, the research showed how absurd is current accounting. Not one company declared segment data sufficient to allow its board of directors to identify profit from this source. How do I know? Because none publish that information and under IFRS 8 – now compulsory -  they would have to if they had the data.

Take Google as an example. It has one segment. In other words its board only review top level data for the company as a whole. They recognise no business sectors. They split the world into US, UK and the rest. That’s it. And apparently they can use this to measure risk and to inform their decisions on allocating resources.

That’s nonsense. It’s impossible to do that.

I’m also challenged to believe that this is true. But since the US version of IFRS 8 has applied to them for some time this is what they say is the case – anything would else would basically mean that there accounts were wrong.

Well tell me this – how do you manage a business on the back of an envelope, as this implies?

And if, as Google says it recognises, selling adult entertainment content is a risk, how come it apparently has no data sent to its board to let it appraise the quantum of that risk?

I worry about this/ What sort of governance does this imply?

Aug 272009
 

IFRS could well fail in the US | AccMan .

IFRS requires (gasp) judgment and that’s something that’s anathema to the US way of doing things.

Dennis Howlett on why the US just doesn’t get the European way of accounting.