Examining Fair Value Accounting in Indian Banking Essay

I. Introduction

Introduction of a comprehensive Fair Value Accounting model for the acknowledgment and measuring of fiscal instruments has been a long term scheme of International Accounting Standards Board ( IASB ) . Consequently, there has been a steady accent on the extended usage of a “ Fair Value ” ( FV ) as the footing for the rating of all fiscal instruments in a bank ‘s balance sheet. Fair Value Accounting ( FAV ) ( besides known as mark-to-market accounting ) has been around for decennaries, but the methods for ciphering just value were inconsistent. In 2006 – in response to investors ‘ demand for consistent, relevant and timely fiscal information – the Financial Accounting Standards Board ( FASB ) adopted Statement No. 157 which established consistent standards for measuring just value in assorted market conditions.

II. Fair Value Accounting

Mark-to-market accounting, a ordinance which mandated the US Bankss to bear more securities at market value, owes its generation to the US nest eggs and loan crisis when losingss on loans were concealed by the usage of “ historic cost ” accounting. Even though FAV has been a portion of GAAP since the early 1990s, the usage of just value measurings has enlarged steadily over the past decennary mostly in response to investor demand for pertinent and disposed fiscal statements that will help them in doing better investing determinations.

Fair value, besides called just monetary value is a construct used in accounting and economic sciences. ‘Fair Value ‘ is defined[ 1 ]as “ a rational and indifferent estimation of the possible market monetary value of a good, service, or plus, taking into history nonsubjective factors such as ; ( a ) acquisition/production/distribution costs, replacing costs, or costs of close replacements, ( 2 ) existent public-service corporation at a given degree of development of societal productive capableness and ( 3 ) supply vs. demand and subjective factors such as ; hazard features, cost of and return on capital and separately sensed public-service corporation ” . FAS 157 defines ‘fair value ‘ as “ the monetary value that would be received to sell an plus or paid to reassign a liability in an orderly dealing between market participants at the measuring day of the month. ” Further, ‘Fair value ‘[ 2 ]is defined likewise under IFRS as “ the sum for which an plus could be exchanged, or a liability settled, between knowing, willing parties, in an arm ‘s length dealing ” . While gauging the just value, IFRS makes comparable differentiations among inputs as FAS 157: Quoted monetary values in active markets must be used as just value when available. In the absence of such monetary values, an entity must utilize rating techniques and all pertinent market information that is accessible so that rating techniques maximize the usage of discernible inputs ( IAS 39 ) . It is established that an entity might hold to do important accommodations to an ascertained monetary value in order to get at the monetary value at which an orderly dealing would hold taken topographic point ( IASB Expert Advisory Panel, 2008 ) . Under both U.S. GAAP and IFRS, just values are most often used for fiscal assets and liabilities.

Harmonizing to FVA, the assets and liabilities of Bankss are carried in the balance sheet at Market Values, if they are available, or at just values estimated as an estimate of the market value by utilizing a Present Value theoretical account for dismissing the expected hereafter hard currency flow. For Bankss, this would connote that the trading and banking books would have equal accounting intervention, whereby all alterations in value would hold to be captured in the balance sheet and transferred to the net income and loss history. The foreseen reappraisal is applicable irrespective of whether a net income or loss has been recognized or remains un-realised since all instruments are either marked to market or the just value is calculated. The disguised militias that might originate under the bing accounting regulations therefore disappear. Therefore, under FVA model, Market hazards would be reckoned during the computation of the value of fiscal instruments in both the trading and the banking book.

The advocates of FVA province that, from a conceptual point of position, FVA government constitutes a realistic attack to fiscal public presentation coverage in order to avoid some of the jobs associated with the current historical cost accounting. One of the advantages of FVA government would be to augment the grade of transparence of fiscal statements. On the other manus, this point of position continues to be theoretical due to the absence of homogeneousness and comparison in FVA methodological analysiss. In add-on, the possible concrete application of a full FVA government ( using to all assets and liabilities ) to the banking sector gives rise to some jobs and concerns.

Applicability of FVA is opined to be in the instance of the trading book of Bankss, which refers to minutess ( purchasing and selling ) of marketable securities and related instruments with the principle of doing a net income from short-run monetary value fluctuations. Making usage of FVA for these minutess is steadfast with the handiness of market monetary values and the short-run skyline. Nevertheless, its usage in the instance of the banking book of Bankss, i.e. to non-negotiable instruments such as loans, comes out to be out of topographic point. On the other manus, the IAS 39 “ Fiscal Instruments: Recognition and Measurement ” , has already broadened the usage of just value in relation to the banking book by obliging the just value reappraisal of assets available for sale.

III. FAV Argument

The Financial Accounting Standards Board ( FASB ) states that its long-run aim of accounting for fiscal instruments is to use ‘fair value ‘ to mensurate and describe fiscal instruments ( Statement of Financial Accounting Standard ( SFAS ) No. 159 ) . Advocates of FVA argue that just values for assets or liabilities reflect current market conditions and hence provide timely information, thereby increasing transparence and encouraging prompt disciplinary actions.

However, FVA is blamed by several quarters of the concern accounting universe for magnifying the Subprime Crisis and the end point Global Financial Crisis, which is considered by many as the worst economic crisis in the United States since the Great Depression ( Ryan 2008 ) . A study by the Office of the Chief Accountant of the SEC for the Congressional commission ( SEC 2005 ) in United States ( US ) states that there are two primary benefits of utilizing FVA. First, using FVA would chair the accounting-motivated minutess premeditated to pull strings the net incomes under the current “ assorted property ” accounting theoretical account ( which is partially at “ historical cost ” and partially at “ just value ” ) , i.e. , chance to prosecute in “ additions trading[ 3 ]“ can be avoided to a considerable extent. Second, fiscal statements developed by using FVA model would be less complex relation to the 1s presently prepared under the ‘mixed property ‘ theoretical account. Landsman ( 2006 ) observes that with all fiscal instruments measured at just value, the ‘hedge accounting ‘ theoretical account employed by SFAS No. 133 would be eliminated. And therefore, investors would no longer necessitate to analyze the picks made by direction to determine what footing of accounting is used for peculiar instruments and at the same clip the house would no longer necessitate to keep records of the fudging relationships.

Some fiscal establishments argue that FVA oblige them to compose down certain fiscal assets to a degree below the value they expect to retrieve in the long term, therefore, gripping them to restrict loaning activities and conserve the capital entirely to follow with the relevant regulative demands. Other stakeholders, including investors and hearers, believe that decently applied FVA provides the most crystalline image of the comparative fiscal status of an organisation, thereby easing the allotment of investing capital to the best performing artists. Few argue that transparence is really critical. But the contention rests on whether FVA in world is helpful in supplying transparence and whether it leads to adverse actions on the portion of Bankss and houses. Oppositions to FVA claim that “ just value ” is non relevant and potentially misdirecting for assets that are held for a long period and, in peculiar, to adulthood. They argue that monetary values could be distorted by market inefficiencies, investor unreason or liquidness jobs. It is besides funny to observe that European Bankss seem more opposed to FVA than U.S Bankss. Contrary to the bankers ‘ positions, investor-interest groups and comptrollers are less disquieted about FVA, even in the current crisis, and advocate against a recess of FVA.

The current crisis has brought to the bow another issue that needs serious consideration, viz. , FVA can do pro-cyclicality. However, making off with FVA and traveling back to historical accounting would non be the right option. Alternatively, capital adequateness and provisioning demands could be made to take into history the cyclical effects of the economic system by presenting higher commissariats and higher capital adequateness during good times so that it would move as a shock absorber during bad times. Another option would be to increase the frequence of revelations along with FVA, so that stakeholders are to the full cognizant of the component of pro-cyclicality in the balance sheet of the Bankss. Further, transporting out emphasis trials based on just values of the balance sheet and unwraping these consequences would do things easier ( Report of CFSA, 2009 ) .

IV. Issues in Fair Value Accounting

In this subdivision of the paper we would wish to foreground some of the issues that need a thorough expression in the execution of FVA. These invite a elaborate consideration on the portion of the regulators before shiping upon the full graduated table execution of FVA.

Management Bias

Managements use important judgements during the rating processes, which add to the concerns about dependability. Management Bias, be it consider or inadvertent, rather frequently would ensue in inappropriate just value appraisals and mis-statements of net incomes and equity capital. Significant write-offs of overdone plus ratings have caused the prostration of few finance companies and depositary establishments. Problems kindred to the above have besides cropped up due to over-valuations in non-bank trading portfolios that resulted in over-statements of income and equity.

Dependability

In instance of liquid and transparent markets, for all assets and liabilities, FVA clearly would be dependable as the information available is justly utile in the determination devising procedure. However, as many assets and liabilities do non hold active markets, the inputs and methods for measuring their just value are more prejudiced. The ratings, hence, would be less reliable. We keep on seeing intelligence narratives about allegations of use of net incomes, even in the instance of historical cost accounting model excessively. In position of this, we can say that, in the absence of dependable just value estimations, the chances for mis-statements in fiscal statements will be even greater.

Confirmation

As the diverseness and elaborateness of fiscal instruments crestless wave, so does the call for independent confirmation of just value estimations. However, hallmark of ratings that are non founded on discernable market monetary values is really demanding. But it is observed that many of the values would be based on information and technique chosen by direction. Estimates based on these direction sentiments would probably be slippery to verify. Consequently, hearers and other users of fiscal statements, like recognition portfolio directors, would necessitate to put important accent on appreciating how the assets and liabilities are calculated and how dependable are these ratings.

Gross Recognition

It is important to observe that the value of a fiscal instrument, in a few instances, is tied with an intangible value. For case, a servicing plus can be believed to reflect two values, i.e. , a fiscal instrument that is comparable to an interest-only strip and an intangible value picturing the contractual right to execute services over clip for a fee. In this background, the accounting model requires diverse accounting and revelations for fiscal and non-financial constituents. However, the accounting literature offers modest counsel on when these assets should be estranged and how to determine the separate ratings. This demand of counsel in few instances might ensue in unsure or awkward patterns. For case, it could be like, including projected income from cross-marketing activities in the appraisal of fiscal instruments. In position of this, farther counsel to turn to these issues is indispensable. Besides, adequate consideration must be assigned to gross acknowledgment issues and it should be ensured that unearned gross is non recognized directly off in a just value government.

Disclosures

One of the statements is that just values reveal point estimations and they themselves, seemingly, do non take to transparency fiscal statements. Consequently, farther adequate revelations are necessary to convey sagaciousness to these just value estimations. Adequate revelations should be good thought-out to supply users of fiscal statements a better grasp of the dependability of just value estimations. Such of the revelations can include cardinal drivers impacting the ratings, just value range-estimates, and assurance degrees. One more critical revelation consideration is related to fluctuations in just value sums. For case, alterations in just values of securities portfolios can originate from the motions in foreign currency rates, involvement rates, and besides from the fluctuations in recognition quality, and besides from purchases and gross revenues from the portfolio. In order to do the users understand just value estimations, we believe that, they have to be given adequate revelations as to what factors caused the fluctuation in just value.

Credit Portfolio Management

In a FVA model, just value estimations do impact the information one uses as recognition portfolio director. Nowadays, fiscal statements are guided by a ‘mixed-attribute ‘ theoretical account harmonizing to which an endeavors ‘ balance sheet may include some values recorded as per historical cost and some others reported at just value. Fair values may be employed as an analytical tool in the loaning procedure and compared with historical cost values. It has to be understood that this historical cost information, along with conjugate revelations, enfolds reliable information that offers penetrations into an endeavor ‘s expected hard currency flows. When the industry moves toward long-drawn-out usage of just value, we believe that revelation of certain historical cost information would stay indispensable.

Bankers positions on FVA during the crisis

During the 2nd half of 2008 when the crisis stepped up alarmingly, bankers raised concerns about FVA for any but the most liquid assets. They contended that FVA was the cause in worsening the crisis by doing a downward spiral and hence market monetary values were significantly below the assets ‘ cardinal values ( US Bancorp, 2008, American Bankers Association, 2008 and Mortgage Bankers Association, 2008 ) . Many outstanding Bankss in U.S. and Europe demanded for a leeway in declaring the minutess disorderly and exchanging to theoretical accounts to find just values based on the implicit in basicss or expected future hard currency flows ( Institute of International Finance, 2008 ) . Furthermore, Bankss in Europe, demanded for the option to reclassify fiscal instruments from the trading class to the held-to-maturity class [ Tweedie, ( 2008 ) and Guerrera and Hughes, ( 2008 ) ] . While this confrontation could be deemed as anecdotal grounds against FVA in fiscal crisis, the statements could besides be viewed as self-serving, basically in go throughing on the incrimination for the crisis to the accounting criterions.

FVA and systemic hazard

Cifuentes, Ferrucci, and Shin ( 2005 ) have, in an analytical model, examined the effects of mark-to-market attacks of fiscal establishments ‘ balance sheets when there are externally imposed regulative solvency demands. It is opined by them that, a daze that compresses the market value of assets carried on the balance sheets of fiscal establishments could take to constrained disposal of assets in order to hedge misdemeanor of solvency ratios. In such state of affairss, in instance, the capableness of the market to absorb such gross revenues is less than perfect ( like that in a macroeconomic crisis ) constrained disposals can widen to a farther short-term autumn in market monetary values. In position of this, under a mark-to-market accounting government when assets are marked down to the new lower monetary values, Bankss could be forced to dispose of more assets to avoid misdemeanor of externally imposed prudential norms. Further continued disposal of assets can foster lower the monetary values and could take to a barbarous cringle of falling monetary values and continued plus disposals. Therefore, it can be opined that the combination of mark-to-market accounting and externally imposed solvency restraints can take to a downward spiral in plus monetary values and turn out to be a cardinal beginning of systemic hazard in the fiscal system.

Fair Value Accounting and “ Contagion ” A inA the Banking Industry

Some of the fiscal analysts contend that FVA exacerbated – or perchance even partially caused the recent planetary fiscal crisis. Harmonizing to them, governmental ordinances require Bankss to keep capital adequateness ratio which is more or less proprietors ‘ equity as a per centum of hazardous assets. When such plus values are marked down to just values, regulative capital becomes excessively low, coercing Bankss to change over some of their “ hazardous ” fiscal assets into “ risk-free ” hard currency in order to hike the ratio described above.A This could take to a “ fire sale ” of assets, which would farther decrease the market monetary values for these assets, doing further mark-to-market write downs by other Bankss, and the procedure starts afresh.A In position of this, single Bankss with a higher ratio of their assets marked to fair value experience greater exposure to this “ contagious disease ” consequence.

VI. Indian Scenario

In the country of fiscal instrument accounting the cardinal distinction between Indian GAAP and IFRS relates to exchangeable debt and penchant portions, investings and derivative instruments. For case, while under Indian GAAP, investings are treated in a different manner based on their categorization into held to adulthood, available for sale and available for trade, they are all by and big required to be treated under IFRS as available for sale and should be expressed at just value. This just value is an issue monetary value which is an appraisal of its hereafter value hinging upon market interactions which need expert ‘s positions.

The aim of fiscal statements in the Indian context has been to supply information about the fiscal place, public presentation and hard currency flows that is practical in doing right economic determinations. Corporate fiscal statements, with the notes and narrations environing them, are meant to enable investors to foretell hard currency flows, happen out returns generated on the capital invested, measure the concern ‘ liquidness, and estimate direction ‘s public presentation. A figure of different measurements are employed at assorted grades and in changing grouping in fiscal statements which include the Historical Cost, Amortized Cost and Fair Value methods. The accounting norms for those assets and liabilities that are held at just value are composite. Presently, in the instance of commercial Bankss and some fiscal services houses, certain plus categories such as marketable equity securities and derived functions, are mandated to be passed at just values. However, for other plus categories like debt securities, loan receivables, it depends on whether the assets are held for trading ( active purchasing and merchandising ) or held to adulthood.

The Indian accounting criterions are by and big aligned to the IFRS, though there are a few divergencies. In India, we are yet to to the full follow the marking-to-market demands as prevailing in the international criterions. The Indian criterions are relatively conservative and do non let acknowledgment of unfulfilled additions in the net income and loss history or equity, though unfulfilled losingss are required to be accounted. Banks are required to mark-to-market the investings in the Held for Trading ( HFT ) and Available for Sale ( AFS ) classs at periodical intervals, on a portfolio footing, and supply for the net losingss and disregard the net additions. This so has proved to be a stabilising factor, in every bit much as it has non induced an instability in the inducement constructions and has besides proved to be less pro-cyclical.

In an progressively incorporate and complex universe market it is necessary that the Indian Banking System should compare its public presentation against the universe benchmarks. Given this background, Institute of Chartered Accountants of India announced that with consequence from April 1, 2011 all listed and public sector entities should meet their coverage systems with IFRS. However, there is alleviation in shop for Indian Bankss. Harmonizing to Y.H.Malegam, Chairman, the National Advisory Committee on Accounting Standards ( NACAS ) , the cut-off day of the month for implementing the International Financial Reporting Standards ( IFRS ) for Bankss, will non be April 1, 2011.The deadline is set to be extended to April 2012 from April 2011 for banking companies.A There will be no concerns because the banking sector is anyhow a portion of Bank of International Settlements. All the dictums by the Bank of International Settlements are translated by the Reserve Bank and are made applicable in India.

Presently, Bankss in India follow the prudential norms of the Institute of Chartered Accountants of India ( ICAI ) and the Reserve Bank ( RBI ) .A Probably, IFRS is expected to impact Bankss peculiarly with respect to derived functions, non-performing loan provisioning, and capital adequateness. Besides, a battalion of technological alterations are necessary for debonair execution of IFRS. There would be greater accent on doing immense revelations by Bankss. Because of these demands, Bankss should get down working on this right now. Adoption of full fledged FVA by Bankss surely would give rise to some supervisory concerns. One amongst such important concerns relates to widening just value as a measurement footing for illiquid fiscal instruments for which there are no evident market monetary values. Notwithstanding several arguments, there is a general consensus that the clock should non be turned back on FVA merely to turn to the issue of impermanent market illiquidity.

VII. Decision

Although FVA methods, entail the Bankss to value their assets using current market monetary values they can stress downward monetary value spirals. In position of this, the attack could be that, the regulations should allow Bankss and fiscal establishments with traded assets to apportion “ rating militias, ” that grow up to reflect over-valuations during upswings and serve as a good buffer against any backsliding to take down values during downswings. Correspondingly, Values of some assets offered as collaterals move with the economic rhythm. In such instances more range is desirable in the accounting regulation book to allow the coverage of conservative ratings, based on futuristic and quantifiable indexs. While leting the Bankss to utilize their ain guesss, the relevancy of the gettable market informations, such as, default rates, prepayment velocities and involvement rates etc. should non be ignored.

To reason, Fair Value Accounting criterion is a good first measure towards making enhanced counsel for the appraisal of just values. Nevertheless, a great trade of work is required to be done in order to do just value estimates more dependable, demonstrable, and auditable. Credit portfolio directors are required to be cognizant of these motions and as to how they will impact their apprehension of companies that they evaluate. In the context of recognition hazard direction Credit derived functions are proved to be utile. However, they raise thorny accounting issues. While FVA option is one promising attack to turn to these issue, promotion of this alternate accounting method should come on in a nonsubjective and sensible attack to guarantee that it consequences in just developments in accounting patterns.