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

 
 
Jan 23

Written by: Jack Ciesielski
1/23/2007 7:30 AM 

Last Wednesday, the SEC filed a civil action against three former officers of ConAgra Agri Products Companies, a unit of ConAgra: former president and COO, James Blue, former North American operations president Randy Cook, and former controller Victor Campbell.

The trio is charged with quite a bit. The suit alleges they perpetrated fraudulent accounting practices including improper revenue recognition for deferred delivery sales and linked rebates from suppliers; omission of bad debt expenses when incurred; and flawed revenue recognition related to advance vendor rebates. Outcome: ConAgra overstated its income before income taxes by about 7.35% in 1999 and 7.85% in 2000. At the segment level, operating profit was overstated by 16.36% in fiscal 1999, and 34.97% in fiscal 2000.

All three defendants benefited from their actions by receiving bonus compensation based on the inflated earnings. The SEC's complaint holds many details of their handiwork, but here's an abbreviated version:

The improper revenue recognition for "deferred delivery sales" is for items sold, but not yet delivered; they were still in possession of goods at the end of the periods in question. This is the "bill and hold" revenue technique made famous by Sunbeam Corporation in the 1990's. It can be accomplished legitimately, but it should be rare: Staff Accounting Bulletin 101 describes the conditions necessary to pull it off properly. Not so in this case - and compounding the faulty recognition, UAP received vendor rebates based on the inflated sales, which further increased revenues. (Wrongly.)

More bad accounting: the provision for bad debts was not stoked while receivables soured . In those two years under examination, the firm avoided $35 million of bad debt expense. Even a plan to write down uncollectible receivables over five years (which is still a violation of GAAP) was rejected by the principals as being too costly to earnings. Finally, the trio was involved with negotiating rebates from vendors in advance of fulfilling the conditions for actually earning them (like selling the vendors' products) and then recognizing them as revenue.

The unit was offloaded to Apollo Management in 2003. The Commission's investigation continues. What's interesting is that these machinations aren't based on some twisted interpretation of an exceedingly complex accounting standard. No, they're just basic blocking-and-tackling issues that had been warped into a work of financial fiction. Bad incentives may have made for bad accounting.




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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.