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The AAO Weblog covers accounting issues and current events as they relate the practice of investment analysis.

 
 
Author: Jack Ciesielski Created: 10/13/2006 2:54 PM
The AAO Weblog is a weblog published by Jack Ciesielski , dealing with accounting issues and news topics related to investment and finance.

You might reflexively think about a possible combination of US accounting standards and international accounting standards, but no - the urge to merge internationally is what's going on at Ernst & Young .

The firm announced the merging of "87 country practices in Western and Eastern Europe, the Middle East, India and Africa into a new EMEIA Area." That's not all: the 700 partners in the Far East practices supported a similar move across 15 countries and territories.

"
The EMEIA Area will operate as a single unit, led by a single executive team and, where allowed by laws and regulations, be underscored by formal combinations of practices. The new Area will be a US$11.2 billion organization with more than 60,000 people. The 3,300 partners of EMEIA will vote on the integration by the end of May. The new EMEIA Area will be effective from 1 July 2008.

The integration of the Far East Area creates a US$1.2 billion organization, with more than 20,000 people. The new structure will also be effective from 1 July 2008.

That doesn't make the firm suddenly bigger or grow more quickly. And it doesn't really change too much for the investor. What's interesting though, is that it gives a couple glimpses inside the auditing world that investors rarely get. First, the sheer size of a Big Four organization is something investors rarely contemplate. The EMEIA area alone will be an $11.2 billion organization, meaning it's hugely important to the firm as a whole: last year, E&Y's global revenues were $21.1 billion. That puts them in the same league as Electronic Data Systems or Constellation Energy Group; ahead of JC Penney or Tyco. Yet investors rarely consider the size and reach of these firms that are acting as their agents in the auditing of financial statements.

The other glimpse: note that these practices were under the E&Y tent, but as different country practices. It's not like all of the firms within the firm are necessarily as uniform as investors might believe. Going forward, there should now be a high degree of consistency and uniformity in the way these practices operate within E&Y. That's something that should matter when say, a Peoria-based audit client has a significant business unit in the Middle East that's audited bythe EMEIA arm of E&Y. Yet investors never wonder much about how the audit gets done until a failure shows up. Nor is there much information available about how the audit gets done.   

Former Fannie Mae CEO Franklin Raines, along with former CFO Tim Howard and former controller Leanne Spencer, settled with its regulator, the Office of Federal Housing Enterprise Oversight,  last Friday.

Recall that Fannie Mae famously abused its accounting for derivative transactions and fee recognition, and has taken years to bring its financials statements back up to the present. According to the OFHEO release, Raines will pay $24.7 million, comprised of:

"The proceeds from the sale of Fannie Mae stock, valued at $1.8 million to be donated to programs and initiatives to assist homeowners threatened with the loss of their homes or related initiatives to assist homeownership, as approved by OFHEO.

Payment of $2 million to the United States Government.

Surrender and relinquishment of claims related to stock options with a value of $15.6 million when they were issued.

Other benefits lost in association with the above estimated at $5.3 million."

It's easy to picture Mr. Raines standing in a corner, with his head hung in shame. In reality, he's probably doing a victory dance: originally, OFHEO had hoped to win $115 million from him. And the Washington Post paints a very different picture of the composition of that $24.7 million:

"The agreement includes stock options worth $15.6 million at the time they were issued; those options are currently under water. They entitled Raines to buy shares at prices of $77.10 and higher. Fannie Mae's shares are currently trading at about $29, so the options Raines is surrendering would not produce any benefit to him unless the share price rose dramatically, according to sources familiar with the settlement who spoke on the condition of anonymity because they did not want to be seen as criticizing the regulator.

OFHEO said Raines's settlement also includes the payment of $2 million to the federal government. That sum would be covered by a Fannie Mae insurance policy, the sources said.

The settlement also includes proceeds from the sale of stock worth $1.8 million, to be donated to programs aimed at assisting financially strapped homeowners. Those are shares Raines had been fighting in court to obtain from Fannie Mae."

Doesn't seem to carry quite the same sting, does it? Not only is the settlement vastly reduced from the original amount of damages sought, the party that Franklin injured - Fannie Mae and its shareholders - wind up picking up the tab for his malfeasance. The terms were similar for Howard.

Is this a great country or what? It's getting to be a weird country, that's for sure.

Last week's Barron's contained a good story  by Andrew Bary on gains being recognized by investment banks on their marked-down debt. I've been a bit surprised by the number of people who've asked about this in the following week: it's not new news. I wrote dedicated reports about it last March, again in June, and once more in November. And it's not as scary as it sounds - Bary's piece was sharp and insightful, and shows that there's a skeptical audience out there when it comes to including such gains in the earnings stream that investors should capitalize. And he quoted some other knowledgable folks who believe this kind of earnings element should not be capitalized by investors.


Got that? D-O N-O-T C-A-P-I-T-A-L-I-Z-E. It's about the same level of quality in earnings that you'd expect from a sale of sale of equipment or a product line. Nobody would capitalize that in the stock price.

"Do not capitalize" is not the same thing as "Ignore." There's still information in those gains - some of it pretty obvious at first, in the case of the investment banks, less obvious if it occurs in something like industrials.

Wrap your head around the concept behind recognizing a gain on a liability depreciation before going too far. Think of something on the asset side of the balance sheet: a debt instrument held by a firm as an investment. The debt instrument increases in value because the company is an improving credit. The appreciation goes into income and it's non-cash. It can't be spent. Market participants probably wouldn't get too excited about that kind of earnings stream; they might figure that it could be easily converted into cash, but they also wouldn't expect it to be necessarily repeatable. On the other side of the balance sheet, if a firm's liability decreases in value, the market for the debt is giving the company an opportunity to improve itself: it'll take less cash to retire some of the debt. Forgiveness of debt is a gain, in anyone's book.

Neither side is a completed transaction  - the firm doesn't sell the debt instrument, nor does it buy back its cheaper debt. Both ingredients go into income anyway, and the investor's job is to sort out what they don't like, as they always have. And the disclosures are good enough that discerning guys like Bary can pick out the skeevy earnings effect. (Another good piece in a similar vein was done by Jesse Eisinger in Conde Nast Portfolio last month.)

The balance sheet is just showing what it's supposed to show: the firm's rights and responsibilities at a given point in time. If the written down debt is available, managers ought to consider buying it in just as if it were stock.

On to the the finer points on the markdown of debt, some additional information it provides: you've got credit markets saying that the firm's prospects stink. That's valuable information that investors should take into account and they wouldn't have it if there wasn't a mark-to-market on the debt. If the credit markets see a freight train coming, one should look for a corresponding writeDOWN of an asset on the other side of the balance sheet - and if there isn't one, they should suspect that one may be coming. This is pretty obvious in the case of investment banks; if you saw something like this happening on an industrial firm's balance sheet, you might be getting an insight you wouldn't expect. Regardless, these gains are not the gravy train the Statement 159 electors think it is.

So far, these are pretty rare: to get this kind of treatment last year, a firm would have had to make an election to do so in the first quarter of 2007. By our count, only 68 firms adopted this treatment in 2007, with financials far and away the majority. More will have a chance to do so in the first quarter of 2008.

I believe we'll soon be hearing about the SEC's plans for allowing companies to use International Financial Reporting Standards here in the United States. The Public Company Accounting Oversight Board, a sort of subsidiary of the SEC that provides oversight of the accounting firms that audit publicly-traded companies, issued its strategic plan on March 31. Some of the goals listed in the document indicate how seriously the PCAOB is taking the pending convergence of US and international accounting regimes. Mentioned as a development that may impact the PCAOB's programs and operations:

"...The SEC has undertaken certain rulemaking initiatives related to the acceptance of financial reporting in IFRS. In particular, the SEC adopted rule amendments allowing foreign private issuers to prepare their financial statements inaccordance with IFRS, without a reconciliation to U.S. GAAP. Based on this rule change, the PCAOB has devoted and plans to continue to devote resources to, among other things, training staff in IFRS. If the SEC were to require U.S companies, or give them the option, to prepare their financial statements under IFRS as opposed to U.S. GAAP, the PCAOB would have to devote additional resources to IFRS training to supplement the training described above, as well as possibly recruiting individuals with knowledge and expertise in IFRS. In addition, the Board would have to evaluate the need for any additional adjustments to its programs and consider the need for new initiatives to prepare for such a significant transition in financial reporting and address any concomitant risks related to public company auditing. In any event, the PCAOB plans to consider its relationship with the International Accounting Standards Board (“IASB”) to stay abreast of accounting developments and enhance the IASB’s appreciation for the effect of its work on public company auditing."

One doubts that this would be at the top of the PCAOB's list of possible developments that could impact its operations if it wasn't likely to become a reality. Also, the PCAOB expects to inspect 72 non-US registered accounting firms in 2008. That number is projected to grow 40% in 2009 to 101.

It seems as if the IFRS groundwork is being put into place, quietly. Stay tuned.

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Also: a hearty, walloping "thanks!" to Business Week for naming The AAO Weblog in its "Financial Blogs: Best of the Bunch" roundup in this week's issue. It's an honor.

If I haven't mentioned it lately, I'll say it again: Statement 157 is nothing new under the sun. While those who would like to blame accounting for their mistakes (and that's what it does: the accounting shows their mistakes) continue to bleat about the unfairness of fair value reporting, the fact remains that Statement 157 had nothing to do with changing the measurement of fair values. It changed the disclosures: now we can look at reported values and know how much they were the results of quoted markets or black magic. It was always that way - it's just that until Statement 157, we never had a good idea of the prevalence of black magic in financial reporting. With all the misguided bashing of Statement 157 going on , it's hard to remember that it hasn't even become effective yet . Not until this quarter. Last Friday, the SEC put in its two cents. The Division of Corporation Finance released a letter it had sent earlier in the month to unspecified financial institutions regarding their pending application of Statement 157. The letter is not an amendment of Statement 157; it's an amplification of Statement 157. The FASB cannot tell companies what to include in the "Management's Discussion & Analysis" section of SEC filings: that's the SEC's turf. Therefore, Statement 157 didn't include any mention of what kinds of disclosures to make in the MD&A. That will be particularly of interest to investors when firms have to use "unobservable inputs" (Level 3) to estimate the fair values of assets. This letter fills that guidance void: "If you conclude that your use of unobservable inputs is material, please disclose in your MD&A, in a manner most useful to your particular facts and circumstances, how you determined them and how the resulting fair value of your assets and liabilities and possible changes to those values, impacted or could impact your results of operations, liquidity, and capital resources. Depending on your circumstances, the following disclosure and discussion points may be relevant as you prepare your MD&A:     • The amount of assets and liabilities you measured using significant unobservable inputs (Level 3 assets and liabilities) as a percentage of the total assets and liabilities you measured at fair value.     • The amount and reason for any material increase or decrease in Level 3 assets and liabilities resulting from your transfer of assets and liabilities from, or into, Level 1 or Level 2.     • If you transferred a material amount of assets or liabilities into Level 3 during the period, a discussion of:           - the significant inputs that you no longer consider to be observable; and           - any material gain or loss you recognized on those assets or liabilities during the period, and, to the extent you exclude that amount from the realized/unrealized gains (losses) line item in the Level 3 reconciliation, the amount you excluded.     • With regard to Level 3 assets or liabilities, a discussion of, to the extent material:           - whether realized and unrealized gains (losses) affected your results of operations, liquidity or capital resources during the period, and if so, how;           - the reason for any material decline or increase in the fair values; and           - whether you believe the fair values diverge materially from the amounts you currently anticipate realizing on settlement or maturity. If so, disclose why and provide the basis for your views.     • The nature and type of assets underlying any asset-backed securities, for example, the types of loans (sub-prime, Alt-A, or home equity lines of credit) and the years of issuance as well as information about the credit ratings of the securities, including changes or potential changes to those ratings." Over at "Notions on High and Low Finance", Floyd Norris worries that a sentence in the letter provides the magic weasel words for companies to avoid writing down damaged goods to an estimated fair value:

"“Under SFAS 157, it is appropriate for you to consider actual market prices, or observable inputs, even when the market is less liquid than historical market volumes, unless those prices are the result of a forced liquidation or distress sale. Only when actual market prices, or relevant observable inputs, are not available is it appropriate for you to use unobservable inputs which reflect your assumptions of what market participants would use in pricing the asset or liability.”

That sounds to me like an invitation to fudge. Some people on Wall Street think that nearly every sale today is a forced sale..." Worth worrying about, but I don't think that's what the SEC meant in the letter. And if anyone tries to use that as an excuse to avoid Level 3 estimation, they should be immediately dispatched to the lowest circle of fair value hell. And anyone who tries to such an excuse in these words will find that hell: they'll be compared to those who don't take the low road. There's only one default position in Statement 157: fair value, whether it's easy or hard to derive. Maybe the SEC needs to clarify that statement.

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So much has been written on the passing of Bear Stearns and its merger with JP Morgan Chase , it's almost impossible to add much worthwhile to the discussion. I would say, however, that the most cogent analysis of the deal-making by the Fed - including the blatant shafting of shareholders - was provided by Andrew Ross Sorkin in his post on the NY Times DealBook blog . And there's a wave of electrons and ink coming your way on the findings of the bankruptcy administrator in the case of New Century Financial, whose 581-page report sent reporters riffling through its pages yesterday. (No, I haven't read it yet. Maybe I'll settle for the executive summary.) There's another story that contains elements of both stories, in a way. Yesterday, the SEC issued a cease-and-desist order to JP Morgan Chase for its negligence in the case of National Century Financial Enterprises, an issuer of asset-backed securities for which JPM had acted as trustee - a role it inherited when it acquired Bank One, which initially had been trustee for the now-failed health care finance outfit. According to the administrative proceedings, during the period of 1999-2002, National Century Financial - whose name is creepily similary to New Century Financial - "offered and sold nearly $3.5 billion in asset-backed notes to qualified institutional buyers. NCFE and the programs collapsed in November 2002 when investors and others discovered that NCFE had made large improper transfers among program accounts and caused collateral shortfalls. The collapse caused investor losses of approximately $2.6 billion." Seems like so long ago now - and so many other asset-backed foibles, it's hard to distinguish them from each other. This one might be memorable for another unsavory reason: the ex-CEO of the firm has been convicted of witness tampering in the fraud trial. How did the fraud take place? In short, NCFE was kiting cash in the reserve accounts of the asset-backed notes: "A principal feature of the scheme that allowed NCFE to hide investor losses was the transfer of huge amounts of Reserve Account funds on or around the first and last business day of every month (“Month-End Transfers”). The indentures required that the programs maintain Specified Balances in the Reserve Accounts totaling approximately 17% of the value of the outstanding notes issued by the program. However, even though the indenture trustees for the NCFE programs had the ability to look at the balances in the Reserve Accounts at any time, the indentures only required the programs to report on the balances in Reserve Accounts as of one day of the month, called the “Monthly Payment Date.” The largest program for which JPMorgan Chase served as asset-backed indenture trustee was reported on by NCFE and tested by JPMorgan Chase as of the last business day of the month. The largest program for which Bank One served as asset-backed indenture trustee was reported on by NCFE and tested by Bank One as of the first business day of the month. As a result of this structure, NCFE was able to kite large amounts of funds back and forth between the programs to make it appear that the programs were maintaining the Specified Balances. In fact, NCFE was consistently and severely depleting the balances in these Reserve Accounts without telling investors." Neither Bank One nor, later, JP Morgan Chase caught on - and that was their undoing: "The Month-End Transfers were large, recurring, and contrary to the requirements of the indentures. In participating in the Month-End Transfers that were contrary to the requirements of the indentures, Bank One and JPMorgan Chase were negligent and should have known that NCFE was misusing the Month-End Transfers." Let's hope that JP Morgan Chase is a bit more attentive to the sensitive details of the far more complicated acquisition of Bear Stearns - and whatever trustee role it will be assuming in connection with Bear's asset-backed obligations. This story should further convince investors that where there's securitized assets, there's bound to be some stink somewhere. And it should also convince investors to run away from investments containing the words "Century" and "Financial" in the name of the issuer. The bard Donald Fagen almost had it right in his "Bright Lights, Big City" soundtrack tune "Century's End": Not "dumb love in the City, at century's end." More like "big hurt in the market, when 'Centuries' end."

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Last week the FASB issued Statement 161, "Disclosures about Derivative Instruments and Hedging Activities." It requires firms to put in their financial statements what should have been in them from the start of Statement 133, back in 2000. Perhaps most notably, it requires this most basic of disclosures:

"An entity with derivative instruments shall disclose information to enable users of the financial statements to understand:
     a. How and why an entity uses derivative instruments
     b. How derivative instruments and related hedged items are accounted for under this Statement and related    interpretations
     c. How derivative instruments and related hedged items affect an entity’s financial position, financial performance, and cash flows."

Simple, eh? If an annual report was really supposed to be an exercise in communicating with shareholders, this would be a natural place to begin. Any illumination on those fundamental issues would help investors - provided they don't wind up being boilerplate. But - an annual report (or an interim report, at that) is not an exercise in communication with the firm's owners. It's an exercise in compliance. It's a shame that it requires a FASB statement to get the most basic communications on derivatives done right.

Of course, it doesn't stop there. The standard also requires much more tabular disclosure about fair values of derivatives positions and the geography of derivative instruments, and gains and losses therefrom, within the financial statement package. For anyone who's ever tried to pick this stuff out of financials, the standard will be a blessing - if proper "compliance" occurs.

We'll have to wait a while to see how effective it is. The standard won't go into effect until years and interim periods beginning after November 15, 2008. While earlier adoption is encouraged, it's not often that firms are fans of increasing their disclosures on most financial instruments. Don't hold your breath waiting for early adopters to pop up in 2008, especially in times of stress in financial markets.




Well, this will be on everyone's mind today. Remember - it shows closing prices through last Friday, when the stock was $30:

  
No doubt, there will be catcalls about mark-to-market accounting because of this. Many critics will say the balance sheet smelled because Bear Stearns held $46 billion of mortgage investments as of the end of November (maybe the last balance sheet we'll ever see for the storied company.) Of those $46 billion of investments, $29 billion were valued using Level 2 inputs and the remaining $17 billion were valued using Level 3 techniques. And with just wild estimates of fair value on their balance sheet, nobody knew what Bear was really hiding and nobody had faith in their balance sheet, and who would dare lend to them without Uncle Sam stepping in, and so on.

One of my early mentors in accounting liked to warn me that "with some folks, a little knowledge is a dangerous thing. And they often prove it." He's so right in this instance. Observers who have learned the fair value hierarchy three-step act as if carrying securities at fair values - even if you have to guess at what they're worth - is something new. It isn't - what's new is that firms now have to tell you how much of the values are mere guesses, and the degree to which they're guessing. Statement 157 didn't require broad new classes of instruments to be reported at fair value - it just required more information about the ones that have been handled that way. For years.

In fact the last accounting standard requiring fair value treatment to be applied to a broad class of financial instruments was Statement 133, "Accounting for Derivative Instruments and Hedging Activities" - way back in 2000. That one didn't seem to touch off any financial meltdowns. Yet  ignorant observers of Statement 157 - which doesn't extend fair value reporting - are blaming it for everything except global warming. A little knowledge really is a dangerous thing.

 I finished up my fifth year on the FASB's Emerging Issues Task Force on TWednesday. My, how time flies.

I've retired, and my financial statement user seat at the table will be more than ably filled by Mark Lamonte, of Moody's. (And a fellow ITAC member, I might add.)

So - a couple thoughts on my time at the EITF. I've said it before: if accounting is considered a branch of microeconomics, then the EITF debates the nano-economics of accounting issues. And I'll reduce all my EITF observations to one analogy: the television program "Lost."

No, that's not a sarcastic or ironic swipe at the EITF. Bear with me, please.

Loyal fans of the show, of which I count myself, look for clues and threads about the show's eventual conclusion in every episode. (Why, if I didn't watch that one hour of TV per week, I'd have a 50% greater output on this blog. That's sort of like the counting of small firms saying that SOX 404 compliance costs would drive them into bankruptcy.)

Back to the "Lost" analogy. I remember reading an interview with the show's creators, where the interviewer was pumping them for any clues or significance attached to a bracelet. The item belonged to an important character that may been connected to another character appearing in one of the show's signature "flash-forward" sequences - the connection being provided by the bracelet. One of the creators threw cold water on that possible connection, saying that "sometimes a bracelet is just a bracelet."

And that is a bit like what I've encountered in my time on the EITF. The EITF spends an incredible amount of time on financial instrument issues. You have a lot of high-powered people puzzling over tiny accounting bracelets, often trying to find a way to see something in a particular financial instrument: is a portion of this promise to pay really equity? Or is it all equity? Or none of it? After puzzling over these issues in the last five years, I believe that sometimes, a liability is just a liability. (Thank you, Damon Lindelof.) 

It'll be interesting to see what happens to the EITF agenda if the FASB and the IASB complete the liabilities and equity project. It might wipe out their agenda; on the other hand, it might sweep in a whole new class of questions accounting for financial instruments. More "Lost" ponderings about the connections to the EITF agenda, if I don't stop here. Have a great weekend!

Required reading for all students of investing: Warren Buffett's annual letter to shareholders. The 2007 version is as witty and entertaining as always. And Mr. Buffett often puts in his two cents on an accounting issue, too - ensuring that investors will take note of it in the year to come. This year's accounting topic: pension assumptions, an issue we've monitored for years at The Analyst's Accounting Observer. Buffett's complaint is that the long-term pension plan earnings rate assumption that corporations use in calculating their expected earnings on pension assets is too optimistic: according to him, in 2006 the relevant S&P 500 companies averaged 8%. Our own work (Volume 16, Nos. 9 & 10, S&P 500 Benefit Plans: Will Pension Panic Resurface?) showed the median return for those companies to be even higher at 8.25% - way down from where it was just five years before at 9.0% and still with some outlandish outliers, but down nevertheless. As Mr. Buffett points out, though, the returns on the different asset classes in the plans don't make sense:      "... The average holdings of bonds and cash for all pension funds is about 28%, and on these assets returns can be expected to be no more than 5%. Higher yields, of course, are obtainable but they carry with them a risk of commensurate (or greater) loss.     This means that the remaining 72% of assets – which are mostly in equities, either held directly or through vehicles such as hedge funds or private-equity investments – must earn 9.2% in order for the fund overall to achieve the postulated 8%. And that return must be delivered after all fees, which are now far higher than they have ever been.     How  realistic is this expectation?  Let’s revisit some data I mentioned two years ago: During the 20th Century, the Dow advanced from 66 to 11,497. This gain, though it appears huge, shrinks to 5.3% when compounded annually.  An investor who owned the Dow throughout the century would also have received generous dividends  for much of the period, but only about 2% or so in the final years. It was a  wonderful century." As usual, the man makes sense - including his larger point about the reason for the bias in the assumptions: "What is no puzzle, however, is why CEOs opt for a high investment assumption: It lets them report higher earnings.  And if they are wrong, as I believe they are, the chickens won’t come home to roost until long after they retire." Does anyone know what the right rate should be? Well, no - you can argue, as Mr. Buffett does convincingly, that rates are too high. But anyone who really KNOWS the real rate to come over the long term would be, more or less, a supernatural being. I don't know any in Corporate America or Wall Street. (Though I've met a number of pretenders.) Figuring the "right rate" is not the real problem. The real problem is that there shouldn't be any expected rate of return for managers to justify in the first place. The accounting methods in place were developed back in the mid-1980's; while an improvement over the (lack of) accounting for pensions at the time, the benefit reporting standard (SFAS 87) was built with many complicated accounting devices in place to keep pension costs smooth. (We've detailed them over the years; check your back issues.) One of those permitted devices: an implicit assumption that the long-term earnings of the benefit plan would average out to some specific rate and letting managers build those assumed earnings into their net benefit cost - a "rebate," if you will, that allowed managers to report lower pension costs. It also allowed them to manipulate that rate to come up with a net benefit cost that they liked. That "expected earnings" never produced cash for shareholders. In fact, the real returns belong to the pensioners, not the shareholders. Pension contributions are pretty much a one-way street: the company making them can't pull them back unilaterally, at will. (There are instances when they can get back some overfunded balances, but it's not simple or easy. Or common.) If the real returns belong to the pension players, why should even the real returns be reported in the income statement as measure of corporate performance? The expected returns were built into the accounting because the real returns would be quite volatile, something that companies couldn't stomach in the '80's (and wouldn't likely want to stomach in this century either.) The real returns really do matter to the corporate sponsor, because they'll be on the hook for contributions if the plan assets fail to fund the promises made - so they belong in the investor reporting package. They just don't belong in the income statement - where the efforts of portfolio managers get mixed in with the operating performance of the company's managers. Instead of cluttering the income statement with the "expected returns" of asset managers for assets that the firm doesn't necessarily control, the REAL performance of the plans might be better reported in accumulated other income - or some other format than what investors receive right now. The FASB is entering Phase 2 of its benefit reporting plan revamp; with the IASB, it's also tackling the revision of the whole financial reporting package. The "expected return" component of benefit costs might be gone as a result of these projects. Good riddance, I'd say. How about you? I'm curious to know what you think and I've arranged a quick 3-question survey at this link, courtesy of SurveyMonkey ...

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