Mr. Isaac would have the SEC suspend the application of the FASB's mark-to-market accounting rules and require that "true economic value," based on a discounted cash flow analysis, be used instead. Mr. Isaac does not define "true economic value," but it is safe to assume that it would be a greater amount than market price, resulting in lesser amounts of loss recognition than under the FASB's methodology. I disagree with Isaac's proposal.
Bank regulators have a different aim and purpose than security regulators such as the SEC. Bank regulators have wide latitude to determine how banks determine capital for bank regulatory purposes. The SEC, on the other hand, requires that registrant-issuers use generally accepted accounting principles (GAAP).
GAAP is aimed at providing investors with neutral, verifiable and relevant information. Market prices of assets are neutral in that all issuers use market prices to determine asset values. Market prices are objectively determinable by reference to facts. And market prices are relevant when it comes to making investment decisions. Prices of assets as determined or allowed by a banking regulator, if those prices differ materially from market prices, have none of those characteristics; those prices are not useful or relevant for making investment decisions.
I urge the SEC not to accept Mr. Isaac's proposal. Investors would not be well served.
Walter P. Schuetze
Boerne, Texas
Mr. Schuetze was a member of the FASB in the 1970s and chief accountant at the SEC in the 1990s.
São dois artigos de Isaac. Aqui o primeiro, de 19 de setembro.
Aqui, o segundo artigo.
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