This is actually a pretty important debate...

If you don't use MTM then it's random until the audit...

The National Society of Art Appraisers has just announced that, henceforth,any painting bearing the signature of an artist will be presumed to be an
original work by that artist. Art values will skyrocket!

Let's all pretend the problem doesn't exist and everything will be fixed by magic! Wish-O-Nomics?

Geepers, Creepers I don't think we'll need more accountants. We'll need to hire an army of statisticians and probability theorists.

You mean Mark to Myth isn't FASB?

ass-u-me

Oh, yeah that'll clean up the balance sheets, nice and tidy.

Can I assume the meaning of "fair"?

Pure conjecture at the moment. Will wager it gets suspended. Will have to see.

Reality is troublesome. Let's assume wild profitability instead.

YouTube - CareerBuilder.com: Monkey Business (Up - Down Profitability) 

CR, if they suspend FAS157, is the bailout still necessary?

Pity this rule wasn't in effect when the value of these things was increasing.

I thought the problem was that we DIDN'T know what things were worth.

This means someone knows... maybe The Shadow.

I am an appraiser and I was wondering how they want me to value the current assets. Should I: A) Take a 5 year average for similar homes in the market or B) What will that house bring today? I vote B. The markets change and if things were so great...Why all the cliff diving. Answer...No More FREE money! Mark To Market is reality based accounting. Can't believe Bush preaching about asstes with artifically depressed valuations.....Come On...IDIOT.

The problem with mark-to-market is that it is pro-cyclical; holders of assets are forced to mark them down precisely at the same time they are running up against capital constraints (or margin calls.) Suspending mark-to-market in favor of cash flow accounting will help dampen cyclicality. But as Dean points out, if they're going to do this on the way down they need to do the same on the way up.

No it means we still don't know what they are worth but the bank gets to tell us what they think it is worth.

Which is what lead to this problem to begin with.

What a joke. If we ban short sellers and go let the financial institutions decide what the value of their illiquid assets are then everything is fixed.

Dow 15,000 -

Once this is all over they will conveniently drop it on the way back up so that bonuses can be paid based on quarterly results.

But as Dean points out, if they're going to do this on the way down they need to do the same on the way up.

Bah, that's a bother. The real point is to keep the bender going, what, do you want the terrorists to win?

"The SEC may say companies can rely more on assumptions ...in assessing how much assets are worth"

I can see what they are trying to do, and trying to prevent...

However, there is that little thing called "transparency", and "investor confidence"...

Law of unintended consequence...

Leave it to the government planners to try and outthink the market.

Transparency builds trust...and it destroys it. Destroying it is also necessary to separate the wheat from the chafe.

If there is even less information about the quality of one's balance sheet out there, how does that impact my lending or investment decision?

I thought Americans liked to keep score.
I've never seen a bigger bunch of babies in my life. "If I can't win then I'm going to change the rules" bah wah wah

Maybe to counter, the, um, countercyclical problem, they could, like maybe take out,I don't know, insurance maybe, from some big insurer to ofset the chance that in, like, a downturn, the price of the underlying assets might fall? How would that work?

who thinks the bailout bill is now really, really dead given the market rally today? Seems like the end of the world never happened.

I am loving this thread

The same bill with one or two changes will be up tomorrow in the Senate and pass.

GillianX writes:
"I've never seen a bigger bunch of babies in my life. "If I can't win then I'm going to change the rules""

Us Americans even have a name for it:

Heads I win, tails you lose.

Geegee,

We can only hope. The markets won't function normally until the expectation of a bailout is gone. That may mean they never function normally again...ever.

This whole issue has little to do with accounting but is really still all about insolvency. Mark to myth will not instill confidence, quite the contrary.

The real problem is that a slowing economy propped up with still easy credit has not been marked to marked yet.

So now it's "Voila, our capital levels are 10X the level required to be well capitalized" without doing a thing ? Assets were already overvalued before this game-rigging operation.

I thought the problem was no trust between financial institutions? This only makes matters much worse. How will international counterparties behave?

Put a new coat of paint on that old wreck and look, good as new! Who gets fooled?

Sounds like they are setting up the system for a mushroom cloud event.

So does this mean no more level 2 and 3 assets? Sweeeet. Zombie banks, here they come.

"Assumptions"....that is great.

Well than as an investor I guess I will just have to "assume" that they are all insolvent.

First, we assume a can opener...

Banning short selling in down markets...

Why not ban going long in up markets too?

After all, we don't want those greedy investors making money off the backs of the suckers who sold too early.

I cannot make values for loans based on a discount for a "bad market". That is bullshit accounting. It is worth what it is worth. If there was value...it would not be such a questionable trade and there would be market participants at some level. The market wants to stay far away from the rigged game until the board is cleared and we can all pass go and get $200 more bucks. Sham, ponzi scheme, crooks, morons, shiesters, snake oil salesmen, whores, pick your term for who was involved. I can tell you an honest man has not had a snowballs chance in hell at making it in real estate. The only way to set a price is to let the free market work. If prices come down 50%....GOOD. Maybe I can buy a house instead of appraising all the McMansions with new Land Rovers but NO furniture.

"who thinks the bailout bill is now really, really dead given the market rally today"

Not me. I think it's more alive than ever. The spin is that the rally was caused by "the hope that the bill will be resurrected". The end of the world is still on, but on hold because of this hope. Or so 'they' say.

Comrades,

Rejoice, level 3 is no longer toxic. In fact it's WAY under valued. They need to mark that stuff up!

Nostrovia,

if they're going to do this
on the way down they need to
do the same on the way up.

Then the pump don't work.

Whole point of a pump is it sucks only in one direction.

@ Peripheral Visionary

Isn't that part of the problem. Changing the rules half way through the game does not inspire confidence.

All it does is make me think that someone is cheating.

The SEC has been horrible all the way through this whole "crisis".

Do the assumptions include the US Treasury buying the assets at hold to maturity pricing?

Wink

When policy follows the essentially random gyrations of daily stock prices, we have a problem.

Let's hope our Congress is smarter than that.

My assumptions for today are (at the moment, subject to change):

  • A fairy-godfather will arrive by pony on my doorstep with a certified check for $10 M.
  • Bush and Cheney will leave office on Jan 20, 2009
  • All banks are sound, liquid, and solvent
  • Hank Paulson will get off his knees and resume dominant posture at GS so Nancy can return the 'fealty' she was given.

Great... banks are scared to lend to other banks because they might have mark-to-fantasy assets on their non-transparent books, and the government's brilliant plan to remediate this is to allow more explicit mark-to-fantasy accounting and less transparency. There's some quote about the definition of insanity which seems particularly appropriate here...

They don't say under what circumstances mark-to-model was allowed. There are certainly cases where mark-to-model gives much better results than mark-to-market. Housing is a great one. First, there's no "market" for an individual house - even in theory you have to use some kind of model. Second, housing markets are often subject to wild boom-and-bust cycles (for those of you who've been under a rock the past ten years) and for a house to be held for a long time an valuations based on discounted expected rents will give a superior predictor.

FUUUUUUUUUUUUUUUUUUUUUCCCCCCCCCC!

I'm finally feeling like the crazies who vehemently opposed invading Iraq and felt like nobody was listening to them!

...meaning the President and Congress (not listening).

So is mark to fantasy going to calm the markets? I don't think so. Isn't the problem that no one knows who is solvent and who isn't.

Duh!!

Note that between 2:00 p.m. and 4:00 p.m. today, the stock market registered a net gain.

Am I supposed to believe that increasing the chance of the Apocalypse through delaying the bailout by one day was a good thing?!

Just nationalize the financial system and get it over with.

Gasparino just said this a part of the Republican plan that Dems wouldn't allow. He said Republicans are claiming that if this happens bailout bill isn't needed

yeah, it's all about the pump

Repubs: We support the free market! (Except for its ability to set prices.)

Wasn't that market end classic?! They can't even close above the .618 retracement on the SPX! Close 1 point higher and they might have a multi-day bounce on their hands, but nope! Panic buying but no price movement - a sight to behold

Mark-to-fantasy is a micro manifestation of a macro phenomenon--the fantastical belief that America has more wealth than it really does.

Gasparino has a really shiny chin. It always looks like he's been drooling just before going on camera.

--
"More work for accountants."

My son is an accountant. SarbOx was a boon for accountants.

"FASB, SEC to Issue Accounting Guidance"

Guidelines for Crooks? crooks have the power to overturn any guidelines, as in stock options accounting in 1995 that led to Scam Options. FASB was threatened by none other than the SEC Chairman at the time Arthur Leavitt.

Jas

"valuations based on discounted expected rents will give a superior predictor."

Yup...ant that's why, in the bubble areas, the "mark to model" house prices are 50% (or more) off of the bubble prices...which nicely coincides with what selling prices would be if you had reasonable loan guidelines (requiring a down payment, no teaser rates, reasonable fico score, income documentation, etc.) Funny how that works out!

All profit is had in the difference between perception and reality.

"the fantastical belief that America has more wealth than it really does."

Yep. That is gonna hurt once it sinks in with the masses.

Jas Jain writes:
"FASB, SEC to Issue Accounting Guidance..Guidelines for Crooks?"

Pirate's Code.

"secondly, you must be a pirate for the pirate's code to apply and you're not. And thirdly, the code is more what you'd call "guidelines" than actual rules."

Banker: we don't need accounting guidance. We've got MODELS!

Oh, and balance sheet marketability levels, too (some hidden, some just made up).

All profit is had in the difference between perception and reality.

All loses are had in the difference between reality and perception

Mark to market doesn't work when there is no market, as is the case with MBS securities today. Therefore, I would argue that mark to model is a valid method. You can value things based on expected cash flows and losses, rather than what the market today would pay for it IF you could even sell it. Seriously mark to market does not work when there is no market!

We are such tools. Just before Uncle Sam gets his wallet out to splurge on the junk yard sale we change the accounting rules to mark the junk upward in value.

This is not hold-to-maturity pricing but rather hold-your-ankles pricing.

So now we are moving closer and closer to Japan and hiding the losses. This is really terrible.

Eventually all the real investors are going to leave the market and you will only have the very uneducated momentum buyers left. That is bubble 101 and this time they are trying to get every last penny of real investors out.

This will crash aggressively.

SR

Citizen Anon, are you saying that if the mark-to-market shows a really bad result, it doesn't work?

Cause I think that means it is working. Just fine.

Assets:

Goodwill - $100 000 000 000 000

Problem solved, no bailout needed. All is well and wonderful again!

If MTM is suspended, then we can jetison the $700B plan that was going to create fake marks, and instead just recapitalize the banks that need capital and aren't walking dead with a more efficient program.

Keeping MTM in effect and having the government create bogus marks seems even more disturbing to me.

I wish the SEC required a disclosure of the default rate, concentration by state and recovery rate of all MBSs... but failing that and given the choice of Mark to bogus government marks vs. mark to fantasy with money being used to recapitalize surviving banks, I go for the latter.

Markets stop functioning when there's a lack of credible information.

Citizen Anonymous writes:

Seriously mark to market does not work when there is no market!

So, you think we should just play... let's pretend this is real, and bank on it while we are at it.

Naw, I don't think so. Pretend is pretend.

Comrade JimPortland08,

"We got MODELS!"

Yes, but do you really think they even KNOW what a CDO is...or a level 3 asset.

I mean come on!

http://i135.photobucket.com/albums/q154/andrea0104/supermodels.jpg

Nostrovia,

When will Google start amortizing advertising costs like AOL did back in the day! That would make earnings look better as well.

Its not just 157, but 115 and 133 that would need to be suspended. Both of those standards require most securities to be marked to market (although sometimes through equity rather than income).

FAS 157 didn't introduce any new fair value measurements, just clarified the rules and provided many more disclosures.

'Level 3' assets existed well before 157, but they just weren't disclosed separately.

Absurd that industry is actually catching the ears of some House Republicans on this.

Also, think about what an "assumption based" rule on accounting would have had in the dotcom era...

Citizen Anonymous writes:
Seriously mark to market does not work when there is no market!

If the models had taken this "black swan" into their formula, you might have an argument. But they didn't and you don't.

MBSs are real just like confederate money-couldn't we ebay them as souvenirs of an historic time?

may i suggest a difference between what exists and what is real?

This will just send LIBOR through the roof. What bank would want to lend to another bank that they know is using the magic 8-ball to value assets?

More work for CPS's...sounds like a good idea to me...since I am a CPA.. Smile

You can value things based on expected cash flows and losses, rather than what the market today would pay for it IF you could even sell it.

As popeye says. Why did the previous models we were supposed to trust fail. I'll assert it's not a "black swan" market, it's a totally predictable market, but there was a dollar in having a broken model.

JimPortlandOR writes:
may i suggest a difference between what exists and what is real?

If you do, I'll miss your point. Seriously, what are you suggesting ?

Seriously mark to market does not work when there is no market!
Citizen Anonymous

Technically you are correct, that if there are no transactions you can't mark to market, but there are some transactions occurring, however at extremely low prices.

GAAP requires that you consider the prices in those transactions in valuing your securities, unless those transactions are 'forced' or 'distressed'.

The very similar idea is in the bailout package, allowing the regulatory capital level to be set to 0%...

This should add some transparency to any company's level assets. Anyone looking to but stock should be greatly relieved.

More cooking up the balance shit....

That should bring back confidence in lending to each other...

what are cps's?


CPA's who can't type!

Confederate money/mark to fantasy abs/loans exist, but they don't nessarily reflect real anything.

Comrade Trainwreck,

"What bank would want to lend to another bank that they know is using the magic 8-ball to value assets?"

Yeah and when they get a no or ask again they raise the value.

Bank: Is it worth $.80

M8B: No

Bank: .85?

M8B: My sourcess are cloudy, ask again later.

Bank: .90

M8B: Chances are excellent.

Bank: WoooHooo! /homer

Nostrovia,

The problem with CDOs, SIVs etc etc was that they did not go far enough.

We need Goodwill Debt Obligations (GDO), Future Invention Vehicles (FIV), Bright Idea Bonds (BIB) and CEO Fucking Up Things Default Swaps (CEOFUPTDS)!

Markets stop functioning when there's a lack of credible information.
barely

One big Gold Star!

Hilipatihippa writes:
Assets:

Goodwill - $100 000 000 000 000

Problem solved, no bailout needed. All is well and wonderful again!

In truth, that's brilliant. And it's pretty much equivalent to the other braindamaged solutions that we've heard.

You sir are a genius.

so we have a barely, a Barley, and a bearly?

Wonder what this will do to the Basil Accords ?

Like I said many moons ago, just move the decimal point to the left a few digits and problem resolved.

Tell me again why we need to spend $700B?

JimPortlandOR writes:
may i suggest a difference between what exists and what is real?

and then writes:
Confederate money/mark to fantasy abs/loans exist, but they don't nessarily reflect real anything.

Most honest disagreements about the market concern disagreements as to time; not substance.

But, I don't think your analogy holds.

mmckinl writes:
Wonder what this will do to the Basil Accords ?

Probably spice them up a little.

Thank you, thank you. I'll be here all night. Tip your waitress.

The IBS will not be amused ...

Comrade citizen scotto

Comrades bearly and barely are the same commenter.

Nostrovia,

friardaddy writes:
Like I said many moons ago, just move the decimal point to the left a few digits and problem resolved.

Left or right?

Peter-san wrote on 09.30.08 at 4:53 pm:

"I wish the SEC required a disclosure of the default rate, concentration by state and recovery rate of all MBSs."

here is some data
US Credit Conditions - Federal Reserve Bank of New York 

the title of the page is
"Dynamic Maps of Nonprime Mortgage Conditions in the United States"

citizen scotto writes:
so we have a barely, a Barley, and a bearly?

I know I like one of their ideas anyways. It's rather like Anonymous.

@ comrade Misean

muchas gracias

Ford and GM should be able to benefit from this. Assuming that their car inventory is worth an additional $25b or so, their balance sheet should get a lot better.

Next we need to work on the Income statement. Real revenue is posting too low because of the short term market conditions. I suggest a market inflator factor to boost revenues to where they would be if SUVs were in demand.

Now we have value and profit forever.

I have a new model for ya'....Folks will pay for an asset when it becomes affordable. The new model will be based on a 50% reduction in home values that saw the 200-400% appreciation rates. Look at Atlanta from CS index..down 5% from peak. That is in line with my daily research of this market. There are areas down 15% and some that had a frenzy of fraud that are off 30-50% with 70% foreclosure rates in the downtown Atl. area. A 10-15% off peak value is a good model and makes a lot more sense than trying to buy assets expecting them to get back to 2006-2007 price levels in the next 5 years. Not gonna' happen unless we get some job creation and see folks save up for a down payment. I would wager in 5 years people will still be trying to pay off revolving credit debt. Reality speaks louder than any politician can scream...MM

the fartnocker crew is going over it now on cnbc

"Lack of credible information"

Heh? I think the information is good - that the banks are broke!

IIRC, the ban on short-selling financial stocks expires October 2. Is that still the case and if so, what are the consequences?

OT but 7 day yield on Fidelity MM FDRXX just went from 2.5 to 2.6

Money Man writes:
I have a new model for ya'....Folks will pay for an asset when it becomes affordable. .....I would wager in 5 years people will still be trying to pay off revolving credit debt.

So, the question is not whether you can find buyers.... the question is whether you should accept their paper as payment.

We built a commercial building in 1985. Our cost was $300,000 and we had a $270,000 mortgage with a local bank at prime plus 1 amortized over 15 years. We also had the facility leased for the term of the loan.

In 1990, the bank called and said they were being forced to reserve against the loan because the RTC/FDIC said the value of our building was less that the principle remaining. It was called "a proforming, non-proforming loan."

We had no intention of selling so we kept the building on the books at cost. Hell, replacement cost was 25% higher by that time.

We still own the building 23 years later with an appraised value of $900,000 and no mortgage.

I understand the arguements for and against and could go either way but sometimes it becomes a sideshow.

Doing nothing can be a real cool hand to play.

Whatever happens, I'd sure hate to be on the audit team or the lead client service partner at any of the major banks right now...

I'm not sure, but I don't think I saw a going concern opinion issued for Lehman Brothers or Fannie/Freddie...OUCH!

Comrade picosec,

"Is that still the case and if so, what are the consequences?"

A less volatile market.

Seriously.

Nostrovia,

Mark-to-the Moon and we'll all be rich. RICH!

level 3=Island of dr moreau assets

Comraades,

They should get insurance from the monolines and get the rating agencies to rate them AAA, then they can put them on the books at par...oh wait...

Nostrovia,

If the data do not conform to the theory, they must be disposed of.

"He said Republicans are claiming that if this happens bailout bill isn't needed"

He's right. Combine this, a higher FDIC guarantee and today's stock market gain and all the ammunition is there for that argument.

All you yammering is amusing to watch. The fact is there is nothing you can do to stop our manipulation of the financial markets, the accounting rules or the political process...

sincerely,

The Bankster Clearing House LLC

Comrade Fraud Guy,

If the data do not fit, you must credit?

Nostrovia,

Doing nothing can be a real cool hand to play.
Ross
~~~~~

Excellent play in an up market ... not so good in a down market ...

mmckinl writes:
All you yammering is amusing to watch. The fact is there is nothing you can do to stop our manipulation of the financial markets, the accounting rules or the political process...

So many wanna be politicians; so few in contact with reality. Sad, but true.

Doing nothing can be a real cool hand to play.
Ross

Hat tip Paul Newma

Hey mom, that smells good... what's cooking?

Your favorite, honey, the books!

Popeye

just quoting ...

The Bankster Clearing House LLC

I'm confused.

Thought that FASB 157 was suspended by SEC anyways.

If so, what's the deal here?

OT, but this stuff is insanely boring but still highly relevant. Example being the changes to the CPI to make it less scary over the years,

Bad data leads to bad decisionmaking.

Now tampering with accounting rules...US markets are soon as transparent as a light year thick wall of solid LEAD. Even accountants working for Mafia will be protesting soon...

Yes Scotto,
A small tribute to Paul Newman.

Anybody ...

effect on the Basil Accords ?

Insightful explanation by a federal bankers on the financial crisis.

A MUST READ!

MarketWarnings: Credit and financial Crisis Explained by Fed Governor from Atlanta

Comrade Misean,

Why does this remind me of the glorious people's five year plans?

Marcy Kaptur says:

We need to change mark-to-market rules to ease credit contraction.

Why Say Nay? - ABC News

calling all bloggers...something...anything... must be done

oops sorry..

Wink

amen and halleleujah

Nemo is always first, when he wants to be.

Comrade Hilipatihippa,

"US markets are soon as transparent as a light year thick wall of solid LEAD. Even accountants working for Mafia will be protesting soon..."

Mob Boss: Hey Numbers, why ain't yous thinkin' up stuff like dese guys, huh?

Numbers: Even I gots my scrupples, boss.

Nostrovia,

I can't say it enough... SHUT down FASB and SIFMA! FASB got us here and they gonna get us out!

As i had commented yesterday, i added to my position amidst sea of despair among CR's acolytes. And lo & behold, market found its bearing today.
There are always a few good men amidst ragamuffins & rif-raff

It's hard to figure. The market wants to jump on passage of the bailout, but there are hard core economic numbers coming down that don't look good at all. Then you get to add your preference on inflation/depression models.

That's right we just ignore treaties when we don't like them ...

Geneva Treaties

Nuclear Proliferation

Basil

Freudian slip there? Ooops

Comrade Fraud Guy,

"Why does this remind me of the glorious people's five year plans?"

LOL!

Because they are the same.

Nostrovia,

Popeye

Unemployment Friday ...

Re: Thought that FASB 157 was suspended by SEC anyways.

No

The proposals would amend FAS 140 to require public entities to provide additional disclosures about transfers of financial assets and also amends FIN 46(R) to require public enterprises to provide additional disclosures about their involvement with variable interest entities.
FASB in April agreed as part of these rewrites to eliminate the Q, an accounting device that has come under much criticism over the past several years, with critics saying the practice has contributed to corporate scandals such as Enron by allowing losing or volatile positions to be obscured.

Markets Media Online - Driven by Content

"Comrades bearly and barely are the same commenter"

But Barley is sure different!

mmckinl writes:
Popeye

Unemployment Friday ...

Yup, but the ISM should look pretty.

Why is my Fidelity Ohio municipal money market paying 5.5%? This is the cash settlement account for trades. Should I be concerned? Seriously, would appreciate the collective wisdom of the board here, since the "overnight" Fidelity money market fund - the one I have to sell out of to go to cash to trade - is yielding 2.4%. I've been having a little bit of luck doing short-term trading of stocks lately, but frankly, I'm not sure what is make of this - I've had brokerage accouts for decades, and have never been in the situation of having to have to dope out the safety of cash equivalent accounts...thanks...carlos

I'll take this horrible choice instead of wasting $700B. How pathetic - choosing between horrible and horrendous.

===============================

The largest single advantage that the Fed has in a financial crisis is that it can act alone. It operates without permission and only the most modest regulation.

Cutting rates to zero will certainly not cost the government and taxpayers $700 billion. It might well free up some of the credit which is currently frozen in place. It would certainly tranquilize some of the market's hysteria. It would leave the impression that there is some will to power left in the institutions put in place to keep the financial world orderly.

Purists would argue that it is not the Fed's job to exercise broad powers. It should have as its sole focus issues of inflation and deflation. It should never be an activist agency. That is the province of the portion of government run by elected officials. Precedent would argue in that direction.

The Fed Needs To Cut Interest Rates To Zero – 24/7 Wall St. 

New York's securities industry could lose as many as 40,000 jobs as the fallout in the credit markets spreads, the state's comptroller warned.
Democratic Comptroller Thomas DiNapoli cited the figures in a release that estimated three service jobs could be lost for every job lost by a bank or brokerage.
“The preliminary September numbers show the fallout from the Wall Street crisis is starting to hit the state hard,” DiNapoli said late Monday. “The volatility in the markets is creating difficulty in predicting budget revenues.”
DiNapoli also estimated that Wall Street bonuses could be as much as 50 percent lower than last year, a drop that “could rival” the lower numbers felt after the 9/11 terrorist attacks.

This is a great start!

Comrade Barley,

"But Barley is sure different!"

Well you get no quarrel from me on that one.

Tongue

Nostrovia,

McCain Adviser: Treasury Doesn't Need Congress for Bailout

McCain Adviser: Treasury Doesn't Need Congress for Bailout

Holtz-Eakin claims law already allows for $700 billion bailout without congressional authority; CNBC's Burnett disputes claim.

By Jeff Poor
Business & Media Institute
9/30/2008 4:45:21 PM

Since the $700 billion bailout plan went down in the House of Representatives by a 228-205 margin, talking heads and politicos have been looking for ways to circumvent Congress and give the executive branch the authority to perform a bailout without their consent.

Republican presidential nominee Sen. John McCain, R-Ariz., first made the suggestion to NBC News correspondent Kelly O’Donnell. His senior economic adviser, Douglas Holtz-Eakin, later confirmed to MSNBC that McCain said Congress has already given the Treasury Department authority to bail out Fannie Mae and Freddie Mac to the tune of a trillion dollars.

“This past summer, Congress passed and the President signed a housing relief bill that had a variety of things in it,” Holtz-Eakin said in an interview with NBC Washington correspondent Andrea Mitchell on MSNBC Sept. 30.

“Among them,” Holtz-Eakin said, “in addition to appointing a new regulator for Fannie Mae and Freddie Mac, that legislation contained the authority for purchases of mortgage-backed securities and other housing-related instruments. It simultaneously increased the debt limit of the United States by a trillion dollars. So in effect, the government could borrow up to – nearly a trillion more dollars and use those funds to purchase these housing-related securities.”

Holtz-Eakin explained this wouldn’t be the first choice of action but said it is an option that is available to the Treasury...

Not sure how I feel about the argument that re-inflating bank's balance sheets is better done with accounting fraud than with taxpayer bailout money. On the one hand, it's less costly and more politically palatable in the short-term, as California figured out a few years ago and has been abusing ever since. On the other hand, it makes it that much worse to try to close down insolvent organizations without exploding all over the rest of the market, and it makes it that much harder for the market to fix itself (ie: inter-bank rates go up further). They're both horrible plans, to be fair, but it's hard to say which is worse than the other.

This is a great start!

I am not going to be gleeful about people losing their jobs, but I think with all the well-educated people getting laid off from finance jobs congress should act to force the AMA and medical schools to vastly increase enrollment next year. That way we can get a lot of this talent into medicine and lower the cost of heath care, which is the real fiscal crisis facing the United States.

Nick writes:
Not sure how I feel about the argument that re-inflating bank's balance sheets is better done with accounting fraud than with taxpayer bailout money.

..... and just think, you're going to get both - rally !!!! Smart long positions will be gone by 11 AM.

Not sure how I feel about the argument that re-inflating bank's balance sheets is better done with accounting fraud than with taxpayer bailout money.

The hell with it. Let's do both. Taxpayer bailout post balance sheet inflating.
Let's play two

Anonymous writes:
http://www.treasurydirect.gov/NP...? application=np

Lets see Public Debt August 'till now

08/01/2008 9,556,571,346,593.61

09/29/2008 9,945,578,231,981.59

Mesenkyme,

There is enough fraud and price overinflation in medicine as it is--let's not move the professionals into the field.

Interesting tidbit from Across the Curve:

"No interest in homes

...though consumers painted a relatively sunny picture about the outlook, they don’t seem inclined to pull the trigger on big ticket items any time soon. Home buying intentions collapsed to just 2.1% of those surveyed, the largest one-month decline since August 1990. Given the tightening in credit conditions in this space it is little wonder to us that pool of prospective buyers is getting thin, not to mention that home prices have sagged by 20% according to the latest Case Shiller numbers out earlier today. Moreover, folks are still not seeing real estate as a great place to sock their investments. According to the University of Michigan survey, only 2% of respondents think home prices are going higher.

Even more disturbing was that new car purchase intentions dropped to just 1.5% of all respondents – an all-time low. This is an ominous sign for those auto sales numbers due out tomorrow – consensus is expecting an almost unchanged print to 13.5 million units while we see sales coming in about 1 million below that mark and we would not be surprised to see sales dip below 12 million in the months ahead.

Those are low numbers, but make sense when very few have down payments ready to put down on these kinds of big purchases.

How interesting...

it seems that just when the market is going to have to face up to reality, it adapts, with the help of 'the suits' like a Darwinian Uber-evolutionista so as to survive and thrive...

whether or not this comes about it is largely irrelevant because it STILL does not address the core issue of confidence at the wholesale level. By what measure can one institution measure counterparty risk when each counterparty can choose the values of its own assets by some measure other than a transparent and standardized one!?!

Can then, I, choose to value the worth of my own assets and liabilities when I fill out a loan application form? Hmmm... I'd say that my 15 years worth of 'Bus Quarterly' magazines is unique and worth a cool $123,456,789....

Gold standard, wherefore art thou?

All the best.

I thought this was in the final draft of HR 3997...
Sec. 132. Authority to suspend mark-to-market accounting.

No?

Basil: Tasty herb.

Basel: Place in Switzerland where they signed banking accords.

Traders get paid based on increases in mtm..

If anything is changed it should be locked in for bonus calc purposes going forward through at least one up cycle.

"That way we can get a lot of this talent into medicine and lower the cost of heath care, which is the real fiscal crisis facing the United States."

I hope that was tongue in cheek. You see the floodgates to medicine were thrown open years ago and it hasn't worked out so well. On the bright side however, there has been a tremendous surge in billing fraud which must be keeping law enforcement busy.

Alba,

It was. I flipped when I saw it.

This issue seems arcane and a sideshow, but is incredibly important. EVERY security is priced through a model – either directly or indirectly. At the simplest level, the value of an asset the net present value of the cash flows from the asset. For mortgage securities, in all of their complexity, read Tanta’s Ubernerds.

A share of MSFT is available for purchase at a price that is a combination of all models – when the results of the model change, price changes. Sometimes it seems it never changes, sometimes it changes dramatically. But the market price at any one instant is an amalgamation of all estimates of value.

But what you need to know is this: the banks have assumptions as to the value of the cash flows based on certain variables such as default rates, recovery rates on defaults, future inflation and interest rates, etc. Potential purchasers have the same models BUT with different assumptions. Since the assumptions between the models aren’t even close, there’s no agreement on price. And we have “frozen” markets and “firesale” prices.

Now maybe the bankers are right and if we price the securities at a market price, it is comparable to taking your Rolex to a pawnshop. Maybe it isn’t a true price. But what we do know is that two presumably knowledgeable parties (banks and potential buyers) have dramatically different values for reasons that aren’t articulated. Someone is wrong. And continuing mark-to-model means we just take the banks word that the bank is correct.

All of this suggests what many here have recommended – slow down and let’s understand exactly what the problem is.

It’s not just accounting.

Anyone catch the ability to reduce regulatory capital requirements to 0% was in the bill?

An innuendo on this point over at Angry Bear, and mentioned above by Gainas, is that this rule change affects how real-economy companies compute their earnings. Any company with slow-moving inventory has more room to pick the number it wants to report. Retailers facing a large loss from a slow Christmas season may try to obscure the fact by overvaluing their unsold goods.

Angry Bear's warning:

Anyone keeping money in the U.S. stock market from this point forward better have no choice.

Ouch.

Can anyone tell me what the heck the DTCC is - other than what is in this article:

WHO REALLY OWNS YOUR MONEY? Part One: The Depository Trust & Clearing Corporation « Your Mortgage or Your Life…

This is scary - scary I did not know of it!

Second, housing markets are often subject to wild boom-and-bust cycles (for those of you who've been under a rock the past ten years) and for a house to be held for a long time an valuations based on discounted expected rents will give a superior predictor.

What question is the accounting rule supposed to answer? I would argue that at least with banks and houses, the question is "What is the current liquidation value of the asset." After all, if the asset is held to maturity and/or the mortgager continues monthly payments. But what a lender or insurer is interested in is not the eventual value if nothing goes wrong. They are interested in what they can get for the pledged security if it needs to be liquidated. If there is a run on the bank, or the borrower loses his job.

McKinl - Basel II framework of accounting standards is a crucial component of US net geopolitical strategy to cement USD hegemony. It's my opinion --since I actually read the BLUEPRINT FOR A MODERNIZED FINANCIAL STRUCTURE-- that the bailout bill is the culmination of so-called short-term [H.R.3221] and intermediate recommendations, a controlled demolition of the US industry which is quite fragmented.

Asset stripping of thrifts continues apace.

US Basel II ruels were finalized 6 November 2007. Goodwin Proctor [law firm] summarized implications of the Quantitative Impact Study 4, commissioned by the BCBS. The study indicated that the BIS version of Basel II would allow certain US banks --ostensibly the twenty FRB primary "broker-dealers"-- a substantial competitive capital advantage over 8,980 other banks, all of which are depositors of the reserve banking system. Another "competitive" tension created by US accord with Basel II is associated with consolidated and country-specific supervision. The BIS-version, which the SEC adopted to regulate FRB primary "broker-dealers" like Merrill Lynch, Morgan Stanley, Goldman Sachs and Bear Stearns, framework for compliance promotes "enterprise-wide supervision" --jurisdiction of a holding company-- over the jurisdictions in which such multinational firms operate.

According to OCC, when the Basel II proposal was issued, Paulson Geithner LLC contemplated that the largest, internationally active US banks ("core banks") would be required to use the Basel II rule. Certain other banks ("opt-in banks") could use the Basel II rule with the permission of their primary federal supervisor. Banks that were neither core banks nor opt-in banks would be subject to some alternative rule. The agreement included a plan to propose a new standardized approach to replace the proposal known as Basel 1A. Although a standardized approach was part of the original Basel II framework, such an approach had not previously been proposed for U.S. banks.

Doubtless Paulson Geithner LLC would like to make the US safe for global debt securities marketing. It's just that it's a little embarrassing for everyone to watch however.

::

Basel II Compliance
Basel II Resources, News, Events, White papers, Services & Products for Corporate Compliance Management

Goodwin Proctor
Basel II and IA: Framework, Issues and Opportunities
summary Banking Agencies Publish Final Rulemaking for US Basel II. - Free Online Library

EVERY security is priced through a model – either directly or indirectly. At the simplest level, the value of an asset the net present value of the cash flows from the asset. For mortgage securities, in all of their complexity, read Tanta’s Ubernerds.

A share of MSFT is available for purchase at a price that is a combination of all models – when the results of the model change, price changes. Sometimes it seems it never changes, sometimes it changes dramatically. But the market price at any one instant is an amalgamation of all estimates of value.

You live in a different world then me. People buy and sell shares of MSFT all the time based on anything from a hunch to an institution that needs it as part of an index fund to possibly something vaguely resembling a discounted cash flow model.

People book MSFT at the market value always and will independently of FAS 157. The market for MSFT is relatively deep and efficient.

Mark to market is great when you are talking about vanilla derivatives with standardized contracts that are bought and sold on exchanges.

When market prices are "modeled" based on a set of assumptions, the answers aren't necessarily better then a model based on reasonable assumptions.

My understanding of this is that the "market prices" they are talking about aren't from looking up the market price of a particular CDO tranche on Yahoo Finance. Rather, they are estimated using so called market inputs.

There aren't real market prices for these things, unless they are sold. Almost all possible buyers are trying to delever. I suppose you could sell them, but the prices may not reflect anything close to a reasonable number. Everyone is on one side of this "market" - the people that are trying to delever.

The total faith in markets I frequently see on here amazes me. They can be pretty efficient and also can be inefficient. The criteria for efficiency include liquidity and depth. Clearly not the case with a lot of this stuff.

Unless you want to assert that ALL markets are highly efficient, just because they are markets -- and that the only criterion of value is what it would likely sell for today, based on something that sold that may be similar, then perhaps there are other reasonable criteria for valuation.

If you look across industries and consider their balance sheets, a lot of assets are NOT valued at market. Plants, equipment, machinery, etc.

I suppose if I thought that modification to "mark to market" meant that anyone could book MSFT at $35 / share, just because they think it is worth $35 -- when it is selling for $25 on a stock exchange -- then I would be upset. No one is remotely suggesting this.

I will be happy to see more serious discussion over this point, because I would like to know exactly what "market" values they want to disregard. I have a strong feeling that the data is thin and is based on inference from something like "comps."

Wanting to have deep, liquid markets is different from actually having them. When you are looking at the exact opposite -- thin, illiquid markets then the information may be of some value but doesn't strike me as an absolute bedrock of accounting truth.

Is a GM plant a "level 3" asset? I dunno. Is cost less depreciation a model? The point is that you can't eliminate judgement by just wanting to have a market price.

Thanks Ed!
Though, have you ever taken your existing car to the new car lot for a trade-in? It's never worth to them, what it appears to you, and Kelly Blue Book. The dealer has fixed costs for turning around a vehicle, and risk mitigation. I sold a '96 Explorer to the dealer a few months ago, after negotiating a new car price over the internet, the salesman never took my car for a spin. Engine sounded great, but it had a cracked head, and would have cost me more to repair than current market value. I'm not saying I made out on the deal, but I surely didn't feel cheated with the fire sale price negotiated. Neither should the holders of unknown value in MBS.

Cars, houses, securities; it's all the same. It's what the market will bear, not what you think its worth. That's why 2 bidders is better than one.

"Rolex to a pawn shop". Now that's funny, I don't care who ya' are. What makes it a Rolex besides quality? Scarcity...there are few of them made. A house is not exactly a Rolex because everybody with a pulse has one and their quality is suspect at best. It's more like taking a timex to a pawn shop, after the shipping truck crashes in front of the store. Compare apples to apples please.

One more thought... a lot of loans were closed on market models called AVM's Automated Valuation Models in leiu of having a human appraiser value the real estate. Those AVM's appear to have been a bad idea. You can manipulate a AVM more than (most) humans and get more loans closed at whatever number you program the thing to spit out.

What question is the accounting rule supposed to answer? I would argue that at least with banks and houses, the question is "What is the current liquidation value of the asset." After all, if the asset is held to maturity and/or the mortgager continues monthly payments. But what a lender or insurer is interested in is not the eventual value if nothing goes wrong. They are interested in what they can get for the pledged security if it needs to be liquidated. If there is a run on the bank, or the borrower loses his job.
Anonymous | 09.30.08 - 7:25 pm | #

GAAP is based on a "going concern" assumption. If you liquidated any business that is profitable, it is highly likely that you would end up with less then the value of the business based on its earnings. Or the discounted cash flow of its estimated earnings. Otherwise, people would just as soon liquidate any business as sell it.

There are plenty of reasons to NOT book things at liquidation value. Especially if they are not going to be liquidated.

In general, a performing mortgage that is in a banks held portfolio -- expected to be held to maturity -- is currently booked at amortized value less a provision for loan losses.

Look at any big bank and how they book their loan portfolio. There has been NO discussion of changing this practice which has been around forever. And they aren't talking about it now.

People may not like it, but the "model" used to book the loan loss provision is reviewed by regulators and auditors and thats the end of it.

I am not going to be gleeful about people losing their jobs, but I think with all the well-educated people getting laid off from finance jobs congress should act to force the AMA and medical schools to vastly increase enrollment next year. That way we can get a lot of this talent into medicine and lower the cost of heath care, which is the real fiscal crisis facing the United States.
Mesenkyme | 09.30.08 - 5:35 pm |

Do you really want a former Wall Streeter operating on you?

I am already over my head here and maybe a real accountant can explain this stuff.

The fear that all businesses will use a change in FAS 157 to "cook the books" is a little far fetched.

On the other hand, one of the main functions of a real security analyst is to review the published financial statements and superimpose their judgment on valuations that may make comparison with peer companies difficult or, more importantly, may not fully reflect the economics of the business.

This has ALWAYS been the case, and published financials should always be the STARTING POINT of a valuation.

Ziggurat writes:
"Look at any big bank and how they book their loan portfolio. There has been NO discussion of changing this practice which has been around forever. And they aren't talking about it now."

Now that every major financial entity is a bank, I have seen it argued that there will be a shift to held-to-maturity valuation of most of financials' balance sheet.

It means that fianncial statements will be much more opaque, which makes stability-oriented regulators very happy. Mark-to-market accounting is a very poor match for deposit-taking institutions.

(feeling nostalgic...)

Why would they change that rule? After all, it's just a bad idea to change horses mid-economy. It's just what the terrorists want us to do.

I found a good summary of the real issue at hand:

"The issue is not whether it has been appropriate for “illiquid assets” in the Level 3 category of FAS 157 to be marked down, but whether the market prices of more liquid indices such as ABX are appropriate proxies for pricing. The wrinkle results from the fact that the underlying constituent securities which make up these indices are not sufficiently liquid to ensure that default protection on those securities is in turn liquidand efficiently priced. As a result, one cannot assume that arbitrage activity will keep the relationships (the “basis”) in line. With this result out of “fair value”, an index of such default protection can, in turn, diverge from fair value — overshooting the level implied by prices of either the underlying securities, or default protection on those securities. Consider an example where the index is trading at 50, default protection on the index’s underlying securities would likely trade around 60 and the most recent trade in the underlying securities themselves was around 70. That 70 price implies certain assumptions about default rates, timing of defaults, recovery values, etc. The 50 price on the index implies more negative assumptions about these pricing inputs. So which set of assumptions is “correct”? Only time will tell. But in the absense of arbitrage activity to keep the various prices “in line” — it’s not clear cut that the index level, despite it’s being the “most” observable, is the most rational.
— Posted by E"

In other words, is a level 2 valuation based on the abx better then a level 3 based on models?

The only answer is that it depends....

And it makes a big difference when you have somewhat arbitrary capital ratios to maintain and fairly subtle judgments can blow you up. This is not even remotely close to ignoring very solid market prices, like a NYSE stock.

The abx is produced by Markit --

"Markit is a financial information services company with over 1000 employees in Europe, North America and Asia-Pacific.

Markit was founded in 2001 as the first independent source of credit derivative pricing"

So how does this credit derivative pricing firm have its indices becoming the required input in valuing complex asset backed securities? Is this stuff robust? Who knows.

I think the issue, as described above, is to allow some flexibility regarding what to use when there is conflicting information. I don't see how the abx is inherently superior.

Or at least how the use of the abx in a situation where there is significant uncertainty should be the only valuation criterion when a firm may be severely damaged by a Level 2 estimate. At least allow a little room for judgment.

Ziggurat,

Point taken.

What I was trying to get at (not very well) was that in a deep market, like MSFT, the value is based on a model or estimate made by every owner and potential owner. A model is nothing more than an estimate of value -- some may be, over time, more accurate than others. Maybe one firms model is cash flow, anothers is astrology, and a third just buys to match an index. But at any point in time, the price is the concensus estimate of value.

If there isn't a deep market (or any market), how, then, do you estimate value? For a GM stamping plant -- at historic cost. For a financial instrument, based on the cash flow. That's what you're buying -- a series of cash payments in the future. You can judge what payments have been made, but you can't precisely determine what paymets will be made.

Owners of these assets can't get what they think is a reasonable/fair/correct price based on their estimate of future cash flows and think that MTM will force them to book a loss on a financial asset that is based on a thin or non-existant market. Maybe this is true or maybe it isn't

If a PE firm will only pay 20% of what the asset owner thinks it is worth, why do they think that? Because they are the only willing buyer (my Rolex at the pawnshop analogy)? Or is their model (and I presume that any potential buyer has an estimate of the value of the asset) markedly different for some reasonable differences in the assumptions?

My point is (and I do have one): the banks want to mark to model. OK. What's the model and what are the assumptions? If they aren't going to accept a market price (for what may be valid reasons), they need to make clear how they are coming up with a value and why it's the one to use. If their valuation is reasonable, and their assumptions are reasonable, why aren't their any willing buyers at a price close to what they think the asset is worth? Maybe 85% of what the bank thinks the asset is worth?

What I'm afraid of is that the banks' assumptions are implausible (e.g. no-doc 2nd's on condos in Las Vegas are money good) and when revealed, will show how bad the situation really is. If they were accurate, I think that there would be SOME market for these financial assets.

I'm not suggeting the market for these financial assets is efficient. Or that any market is efficient. What I am thinking is that if they have a financial asset that is worth X, and X can, within a range, be objectively defined, why are there no buyers at anywhere close to that price?

Does that make sense? And why I think it's a big deal that MTM is being dismissed? Are their really no bids -- or no bids that will not reveal that the emperor has no clothes?

Ziggurat,

Excellent post. 9:57 was posted after you -- I agree.

I actually think we are in agreement -- I don't object to mark-to-model; I think that we have to have a better understanding of what's going into the models. My real concern is mark to model + 0 reserves leaves everyone in the dark (Does BofA know how WFC has modeled its assets? Is it safe to lend to? We now don't have any reserves).

It just appears to be a way to sweep the problems under the carpet at a time when we need more transparency, not less.

Ziggurat,

I understand that illiquid markets produce unreliable prices, but I am very suspicious that only now are 'people' determining that the prices that are available are unreliable.

Another explanation for what's happening is that the true market price of many assets is going down for valid and good long-term economic reasons, and the people who hold these assets don't want to suffer the consequences. (By the way, they had no problem when the assets were going up in price.)

Very difficult for me to believe that after 13 months with no market for many of these assets (at the prices the banks will accept) that the prices are acceptable for accounting purposes. If the market has disappeared for those products for that long, then they are worse than worthless because they are taking up precious capital to hold on the balance sheet.

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