<i>Cid Yama: I believe the gutting of FASB Statement 157 was not intended just to postpone the marking down of banking assets and allowing the banks to survive another quarter. Rather, I believe there is method to the madness of the SEC's opinion letter of March 28th(now backdated to Jan 1st).</i>
Fifteen years ago, the US government devised a clever trick in the aftermath of the savings and loans crisis, by conducting firesale auctions of S&L assets. This was brilliantly effective in establishing clearing prices and turning sentiment around, because as soon as investors saw some assets being sold at knockdown prices they starting jumping in, meaning that within a few months, prices were rising again.
But these days the US government faces a crucial impediment to repeating this trick. <b>Back in the days of the S&L crisis, US banks were not forced to mark their books to the firesale prices.</b> But now the mark-to-market creed has taken hold. And it is a fair bet that if US banks were forced to mark their books to the initial clearance price for a CDO squared, say, some would run out of capital. Hence the trap: in the modern financial system, you can have mark-to-market accounting systems, or quick action to establish clearing prices, but probably not both, without blowing up some banks.
<b>Of course one way to exit this trap would be to abandon the mark-to-market rules for a while</b>, or loosen capital adequacy standards.
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<b>Return of Mark-to-Make Believe</b>
As we all know, the G7 financial authorities are fighting tooth and nail to rescue their financial systems. The bottom line of it is that they are INSOLVENT and require balance sheet repair of epic proportions. It will require a combination of MONEY printing, hocus pocus, smoke and mirrors and changing the rules -- whether it be the changing of balance sheet requirements at Fannie and Freddie, the expansion of the home loan banks, term lending facilities of one sort or another or opening the borrowing windows at the fed wider and wider in terms of eligible securities of participants (investment banks) which can access the lending.
In the last 6 weeks we have seen over 1 trillion dollars in combination of all of these things added to the pool of liquidity to underpin asset markets. Now comes the latest twist: “The return of marking to model” which was ended last November. Tedbits wrote about it at the time and it has bitten the banks and financial industry’s balance sheets HARD.
This is a picture of financial industry and banks’ balance sheets VAPORIZING before our very eyes. So what do the financial and banking authorities do? What else? Rewrite the regulatory guidance in respect to how to value them for REGULATORY reporting purposes. The SEC has issued an opinion letter informing financial and banking companies of how to deal with these thorny balance sheet and accounting compliance issues by telling them if they have a problem with the mark to market valuations then <b>declare the prices as the result of forced liquidation</b> and ignore them.
And how did they sidestep the horrendous losses due to be reported in the next three weeks from the 1st quarter? By backdating the interpretative notice back to January 1. Abracadabra: poof and money reappears on the balance sheets, hocus pocus of the highest order. That rule saw the light of day for a total of 45 days!!! Now it’s history.
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<i>And this is the colonic to get those conduits moving again.</i>
<b>Securitization is Officially Dead</b>
It appears that the FASB has removed the concept of QSPEs, which is the enabling "piece" to make off-balance-sheet securitizations possible, from the FASB set of regulations, specifically, FAS 140.
As such it appears that all financial institutions will have to reclaim all SIVs back onto their balance sheets no later than the start of 2009.
This is a watershed event.
In short Investment Banks have ~6 months to get their act together and their capital up, and then they are going to have to start integrating these vehicles back onto their consolidated financial statements.
http://www.tickerforum.org/cgi-ticker/a ... post=38608
<i>This should be more than enough incentive to get that firesale moving.</i>
I want to say, I whole-heartedly endorse this solution, as some banks will survive their folly, but not without a great deal of loss and pain. No one will be able to call this a bailout.
P.S. With the Fed having taken alot of this stuff as collateral, they may be the first seller to get the ball rolling. It all looks like it was planned now. I may get up and applaud Bernanke before this is all over. The banks won't like him very much though.
"For my part, whatever anguish of spirit it may cost, I am willing to know the whole truth; to know the worst and provide for it." - Patrick Henry
The level of injustice and wrong you endure is directly determined by how much you quietly submit to. Even to the point of extinction.