FASB to Make Dramatically Favorable Changes in Mark to Market Rules

It looks likea return to mark-to-assumptions is in the cards. The prospective rule change is targeted at large banking institutions with hold-to-maturity MBS portfolios.

This rule change will be generally known as marked-to-official-policy accounting, wherein our desired objectives are achieved by definitional manipulation and corporate decree. This is consistent with our national currency.

If the holder of a financial asset cannot obtain an active price, they can assume the cash flows will be maintained to maturity and value the asset based on that.

This is not decided yet, but we would imagine FASB is under intense pressure from the federal government and the banking lobby.


FASB to Propose Improvements to Mark-to-Market and OTTI
The American Banker
March 16, 2009

The Financial Accounting Standards Board agreed today to propose alternatives for improving mark-to-market accounting in illiquid markets and for “other-than-temporary-impairment” (OTTI). ABA has been requesting improvements to these mark-to-market issues for the past year and for improvements to OTTI for many years.

Mark-to-Market.

The proposal for estimating market values will take into consideration whether there is an active market (such as the number of recent transactions, whether price quotes are based on current information, whether price quotes vary substantially, etc.). If there is not an active market, then the quoted price is a distressed transaction unless certain other conditions exist. For distressed transaction prices, “Level 3” techniques (such as present values of future cash flows) are used instead of the distressed prices and should reflect an orderly transaction between market participants, including a reasonable profit margin for uncertainty in a non-distressed situation.

Other-Than-Temporary-Impairment.

FASB will also propose that the full market loss continue to be reported through earnings (and capital) only if the entity intends to sell or will be required to sell the security prior to its recovery. For all other OTTI, the amount of market loss will be split between the credit portion of the loss, which will be reported in earnings, and the remainder of the loss, which will be reported in “other comprehensive income.”

Effective Date and Comment Period.

The proposed effective date is for periods ending after March 15, 2009. However, FASB is concerned that some may not be able to prepare the information in time for March 31, 2009, reporting, and will request comments on whether it should be effective for periods ending after June 15, 2009, with early adoption (for March 31, 2009) permitted. Comments are due April 1, and FASB hopes to make its final decision on April 2.