Regulation, valuation and systemic liquidity

It is a commonly held view that International Financial Reporting Standards (IFRSs), adopted by the European Union in 2005 and by other jurisdictions, compounded the recent fi nancial crisis. Application of the IAS 39 rule that governs loan-loss provisions and extends mark-to-market valuation of assets meant that when credit prices fell sharply in 2007 and assets were revalued using the new lower prices, it triggered a need for institutions to raise capital by selling assets, which pushed prices down further, causing more revaluations and more selling in a vicious circle. Mark-to-market volatility added to this unstable dynamic by keeping new buyers away. Fair value accounting rules are pro-cyclical and can contribute to the systemic disappearance of liquidity.1 The price of assets if they were to be sold immediately fell substantially below the price of the same assets if they were to be held to maturity or for some time period beyond the crisis. This liquidity premium was no longer a fraction of a percentage point, but tens of percentage points. A number of observers have concluded that mark-to-market accounting should be suspended during a crisis. On its own, I believe this initiative would further weaken incentives for responsible lending in the good times. Nor would it solve the problem in bad times. The pro-cyclical use of market prices is not the preserve of accounting standards –it also lies at the heart of modern financial regulation. Financial crashes are not random. They always follow booms. Offering forbearance from mark-to-market accounting or other rules during a crisis, yet using these rules at other times, such as during the preceding boom, would promote excessive lending and leverage in the good times. This asymmetry would contribute to more frequent and severe crashes. Second, crises are a time where a rumour becomes a self-fulfilling prophesy, as panic and fear spread. It is, arguably, not the time to generate a rise in uncertainty by changing accounting standards. There is room for a revision to the application of mark-to-market rules, but not a revision based on relying on the messenger’s every last word in good times and shooting him in the bad times. But the mechanisms that lead market participants to greet price declines with sell orders have not all to do with value accounting. Current prices, including spot and forward prices, play an important role in the market risk and credit risk management systems approved by financial regulators. Risk limits and sell orders are triggered in response to a rise in price volatility and/or a fall in price. The very philosophy of current banking regulation –risk sensitivity– is about incorporating market prices into the assessment and response to risk. It should be no surprise that if prices, both prices for current and future delivery, are pro-cyclical, then placing an increasing emphasis on price in the management and regulation of risk, will lead us to systemic collapse. This article examines the role of valuation and systemic liquidity and argues that an approach to how we apply mark-to-market accounting and market prices or risk that is driven more by an economic view can improve the systemic resilience of the fi nancial system.