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

 
 
Nov 21

Written by: Jack Ciesielski
11/21/2005 9:19 AM 

No, not the holidays...

It was just about this time last year that the "Great Lease Restatement" was kindled, instead of the fireplace. A year ago this Wednesday, CKE Restaurants filed its 8-K indicating there were problems with its lease accounting, the first one of any note. Gradually, more and more firms started restating; mostly KPMG clients like CKE Restaurants, then other firms. (Note: KPMG is a subscriber to The Analyst's Accounting Observer.) Eventually, the letter that launched a hundred restatements was issued by the chief accountant of the SEC.

Back to the question: is it that time of year again? Maybe; in the last month, there's been a brace of restatements having to do with failed hedge accounting using derivatives.

Last Thursday, Pride International filed a non-reliance 8-K indicating that had incorrectly accounted for swaps and caps as an integral part of certain loans rather than as discrete derivatives. Proper accounting would have marked the instruments to market, with changes in fair value going through other income. (Their auditor was PricewaterhouseCoopers.) In late October, Kilroy Realty also indicated that their hedge accounting needed to be revised: their documentation of hedge accounting was insufficient to allow hedge accounting treatment, but the 8-K offered few details on what was lacking. Their auditor was Deloitte & Touche.

Also in the last couple weeks, three regional financial institutions reported on non-reliance 8-K filings that their use of the "short-cut method" of testing hedge effectiveness was incorrect. The institutions: Pulaski Financial, Provident Bankshares, and Taylor Capital Corporation. Going back into late October, South Financial Group filed a non-reliance 8-K for the same reasons. All four of these institutions share KPMG as their auditor.

Time out for a very quick background on the accounting issue here. When firms use derivatives to hedge a risk - say, the fair value of a brokered CD or an interest rate swap - they have to designate (by documentation) that such a hedge has been created and they must continually monitor the effectiveness of the hedge. "Effectiveness" means that the relationship that was set up between the hedged item and the hedging derivative instrument is still working at later reporting periods. If the effectiveness no longer exists, the hedge accounting is discontinued and any gains or losses on the hedge accounting are reported in period's earnings where the hedge accounting failed. This is a lot of follow-up and documentation that firms would prefer not to do; for obvious reasons, such testing of the relationship is called "long-haul" testing. There is an alternative built into Statement 133 called a short-cut test for effectiveness. At its core, it assumes that a cash flow hedge or fair value hedge is effective if it meets the (many) criteria listed in paragraph 68 of the standard. Meet those criteria, and no long-haul effectiveness testing needs to be done. Effectiveness is presumed.

This is where the four institutions had their problems: their didn't actually qualify for the shortcut treatments. They'll all go back and restate earnings with the changes in fair value of the derivatives flowing through earnings. Two of the firms - Provident and South Financial -said that going forward, they'll re-designate the derivatives as hedges and use "long-haul" testing to monitor effectiveness and regain hedge accounting treatment.

There's certainly a sense of deja vu here, what with the time of year and the KPMG presence. It's way, way too early to expect a restatement trend for termination of "short-cut" derivatives accounting. For now, consider it a coincidence.


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Pension & Other Benefit Plans: A Look Ahead


    Investors in firms with defined benefit pension plans always face the risk of suddenly being pushed farther back in line when it comes to being served their returns. Variability in plan assets and variability in benefit plan obligations are the reason: poor asset returns coupled with sinking interest rates always spell tough times for defined benefit plan funding. In that regard, this year’s asset returns combined with the Fed’s “Operation Twist” add up to “Operation Agony” for defined benefit pension plans. If trends continue along their current path, firms that may have anticipated moving to more realistic pension accounting - like Honeywell, AT&T and Verizon already have done - might forego that decision. It could be just too painful. 

    Pensions aren’t the only kind of benefit plan affected by Operation Twist. Other postemployment benefit (OPEB) plans share much the same accounting model as pensions, including the calculation of a projected benefit obligation that similarly incorporates a discount rate - one that will also be affected by Operation Twist. The net OPEB obligations were slightly less than pension obligations at the end of 2010, but also promise to grow in 2011. Investors perceive them as less threatening than pension obligations because they don’t require funding. Strangely, there are a number of firms that are recognizing income from these benefit plans - without ever creating a dime of cash for investors.

A recent edition of The Analyst’s Accounting Observer dissects these issues, and is available only to paid subscribers. A condensed version is available for free upon request. To receive it, send an e-mail to Brenda Rappold at brappold@accountingobserver.com, with “PENSIONS” in the subject line.

For information about subscribing to The Analyst’s Accounting Observer, click here.