Volume 12, Issue 2 - Unreliable Accounts

In 2010, the U.S. accounting rulemaker (FASB) updated its longstanding constitution to eliminate “reliability” as a fundamental accounting property. FASB argued that “reliability” was misunderstood in practice and that this amendment clarified its original intent. Drawing on primary archival resources and field interviews with regulators, I provide evidence that the change also sought to legitimize the rise of fair-value accounting. By eliminating the need for accounting to be “reliable,” the change attempted to neutralize concerns about the subjectivity in fair-value estimates. Such subjectivity can facilitate accounting manipulation, and some fair-value rules can be attributed to lobbying by managers who stand to benefit. The change illustrates “conceptual veiling,” wherein regulators, seeking to diffuse criticism, including suspicions of capture, manufacture costly conceptual narratives for justifying their actions.

Ramanna (Unreliable accounts: How regulators fabricate conceptual narratives to diffuse criticism. Accounting, Economics and Law: A Convivium , this issue) argues that the FASB’s new Conceptual Framework deemphasizes reliability, and especially verifiability, in favor of representational faithfulness to facilitate the FASB’s promotion of an “asset-liability” approach measured at fair values. More importantly, he argues that this change is likely to generate costly unintended consequences by undermining reporting quality. We agree and consider more broadly whether FASB creates social value through better accounting knowledge, and whether it is time to sunset the FASB monopoly in establishing accounting standards.

While the FASB had regarded relevance and reliability as two of the most important qualitative characteristics for years, it replaced reliability with faithful representation revising its Concepts Statement No. 2 in 2010. Even if fair values are relevant for the measurement of assets and liabilities, these figures are not necessarily reliable or verifiable. We believe this point is the central message of Ramanna, K. (2022). Unreliable accounts: How regulators fabricate conceptual narratives to diffuse criticism. Accounting, Economics and Law: A convivium forthcoming. The application of fair value measurement has been substantially extended recently to income recognition of not-for-trading financial instruments and even non-financial assets. Is this extension due to the primacy of relevance over reliability, or the relaxing of requirement for reliability toward faithful representation? Whatever measurement method we use, it is absolutely necessary to construct a system of concepts on which the purpose of measurement should be established. In spite of the fact that any measurement method is a means to intended purposes, if we first chose a particular method and applied it to every situation slavishly, we would become similar to a bogus doctor selling a fake drug as panacea valid for any disease.

The theoretical foundations of Karthik Ramanna’s “Unreliable Accounts” are investigated, demonstrating the pluralistic approach which underlies his critique of the accountability and governance of the FASB. In particular, I highlight Ramanna’s use of multiple units of analysis and theoretical frameworks in his arguments for the existence of conceptual veiling, but I question the extent to which extent Ramanna’s account can be viewed as a generalisable causal explanation. Finally, avenues for future research are noted.

This paper serves as a commentary to Professor Ramanna’s paper, “Unreliable Accounts: How Regulators Fabricate Conceptual Narratives to Diffuse Criticism.” The case analyzed by Professor Ramanna is the case of CON 8 in which the FASB changed the qualitative characteristics originally identified in CON2 to eliminate the concept of reliability from those qualities accounting data must possess before such data is decision useful. This commentary intends to add some historical depth to the particular case analyzed by Professor Ramanna to demonstrate that conceptual veiling has been a continuous process since the FASB’s original concepts statements that created a conceptual framework made up of two conflicting narratives, i.e. a mixing of the language of two metaphors for accounting. These two metaphors are “accountability” and “information.” The fateful error that has plagued the concepts statements with incoherence since the FASB began was the repurposing of accounting to that of “decision usefulness.” Decision usefulness as defined by FASB had to contain the property of prediction, explicitly predicting the timing, amount and uncertainty of cash flows. However, information is always “about something;” it is not a free-floating abstraction. Since knowledge about the future in economic affairs has eluded the ability of economists and likely always will, FASB is allegedly providing information about the future for which is has not any noteworthy expertise. CON 8 is just another stage of the growing incoherence of the concepts project. The norms of double entry accounting that developed over centuries and shaped accounting’s fundamental concepts served the purposes of accountability for which information to be information must be reliable. The entire edifice of science would collapse if scientific information were not reliable. Without reliability, the boundary between information and misinformation is blurred to the point of invisibility. Professor Ramanna’s analysis provides great insight into the absurdity standard setters now endorse that information does not have to reliable!

Karthik Ramanna’s article titled “unreliable accounts: How regulators fabricate conceptual narratives to diffuse criticism” provides a critical insight into how Fair Value Accounting (FVA) was incorporated into the conceptual framework for general purpose financial reporting. Karthik reveals that the installation of FVA into the FASBs constitution can be understood through a framework: conceptual veiling. In this framework, the FASB is captured within the logics of financial market economics, assuming investors and capital market actors are best served by financial disclosures that reflect market valuations. Captured by these interests, the FASB needed to modify the narratives contained in the conceptual framework removing reliability and substituting faithful representation because much of what constitutes FVA disclosures are estimates and judgements of questionable reliability. A more forceful critical evaluation of the re-orientation of accounting practise from Historical Cost Accounting to FVA might have located changes in the context of the financialized company.

Karthik Ramanna in ‘ Unreliable accounts: How regulators fabricate conceptual narratives to diffuse criticism ’ considers how the Financial Accounting Standards Board (FASB) justified a conjunctural break from historic cost accounting (HCA) to Fair Value Accounting (FVA). Karthik’s paper explores how the US Financial Accounting Standards Board (FASB) legitimized the introduction of fair value accounting (FVA). This fundamental reorientation of financial reporting practice can, he argues, be understood within a framing device: conceptual veiling. Firstly, the FASB is (suspected to be) captured by the interests of investors and capital market actors. Secondly, the FASB needed to construct new narratives to enable this reorientation in accounting practice and this was achieved with changes to the governing conceptual framework. An alternative framing device is offered in this review, that of the financialization of company financial reporting and implications for company viability as opposed to a capital market efficiency perspective. Financialized accounting facilitates the valuation of a range of asset classes to a market value. These asset valuations are speculative in nature. FVA accounting imports speculative capital market risk onto company balance sheets and this can threaten company financial stability and viability for a going concern.

Karthik Ramanna recounts how the Financial Accounting Standards Board (FASB) dropped “reliability” as a fundamental property of accounting in 2010. He offers two possible explanations for this change: (1) The FASB removed reliability to clarify its conceptual framework, and (2) It sought to reconcile its framework with the growing use of fair-value accounting. Ramanna does not give total victory to one explanation over another, nor does he assign purely public- or private-interest motives to the actors in the story. Yet this very ambiguity tells us a lot about the distinctive politics of accounting and other technical realms of regulation, and exposes some of the shortcomings of more standard interest-group models in political science.