If you think you can find a larger wart on the backside of US GAAP than the one I am about to describe, then give it your best shot.
Here it is in a nutshell: a careful and cynical application of the foreign currency accounting rules (either US GAAP or IFRS) could result in a $10 million bank account balance being reported on the balance sheet at $25 million. That’s right: balance sheet cash isn’t the cash balance. I double dare you to top that one!
As you may have guessed, the rules I am referring to are part of FAS 52, Foreign Currency Translation (now Topic 830 of the Codification), which was finalized by a 4-3 vote. They have sat there unremarked upon for thirty years, until relatively recently as negative economic developments in Venezuela have elevated them from a few ounces of cream cheese on a bagel to six tons of chopped liver on a Ritz cracker.
So, into the muck gingerly wades the SEC with new guidance in the form of a staff announcement at a recent meeting of the Emerging Issues Task Force. The FASB has codified that guidance with the issuance of ASU 2010-19. As you’ll see, the SEC’s message to investors is ambivalent, to say the least, on an issue that is as black and white as it gets.
Setting the Stage for the Big Whopper
You may wish to refer to a related post, which I wrote almost 3 years ago, and in which I described how consolidated financial statements could actually report foreign exchange gains and losses on U.S. dollars. Here’s an example from that post, albeit slightly tweaked, to set the stage for the whopper to come.
Alpha Co. is based in the U.S. and presents its financial statements in U.S. dollars (USD). Beta is Alpha’s Venezuelan subsidiary, and its functional currency is the local currency of Venezuela, the Bolivar (VEB). Inflation has been high in Venezuela in recent years. For this reason, Beta holds its cash balances, worth $10 million, in USD-denominated accounts. Also, as a result of the high rate of inflation, the VEB has been steadily devaluing against the USD.
For simplicity, let’s assume that the cash balances I mentioned are Beta’s only asset. Under normal circumstances, this is the way that consolidation of Beta with Alpha would work:
- The USD cash balances held by Beta would be “remeasured” into VEBs; the resulting gain (because the VEB is losing value) would be reported on Beta’s income statement (in VEBs).
- Beta’s VEB financial statements (including the gain on holding USDs in Venezuela) would be “translated” to dollars for the purpose of consolidating Beta’s financial statements with Alpha’s.
- The effects of the “translation” process on equity would be reported in a separate “translation adjustment” category, which would not affect income.
Thus, although total owners’ equity does not change from the roundtrip that the USD is taking in the accounting records — USD Þ VEB (on the sub’s books) Þ USD (in the consolidated financial statements) — the gain from the outbound leg of the trip would be reported in income, but the loss from the homeward leg would bypass the income statement and only be reported in a separate component of owners’ equity, i.e., the so-called “translation adjustment.”
Of course, it’s a ludicrous outcome buttressed by extremely flimsy logic, but I have already beaten that drum. Here comes the whopper I’ve been fixin’ to tell you about.
The Dual Exchange Rate Problem
Even if you absolutely detest the effect of FAS 52’s remeasurement/translate procedures on reported earnings, there is the small consolation that cash (and other monetary items) are correctly stated—even after their round trip. However, this is not always the case for two reasons: (1) currency exchange controls by the country in which a foreign subsidiary is located; and (2) more bad accounting rules.
As to those currency exchange controls, they can result in multiple exchange rates. Here, for example, is how the SEC staff, in ASU 2010-19, describes the current situation in Venezuela:
“[C]urrent restrictions of foreign currency exchange in Venezuela provide that entities use the official rate of exchange to exchange funds…. As an alternative to the use of the official rate it may also be legal to utilize the parallel rate. It is possible that the parallel rate provides entities with a more liquid exchange and entities can access the parallel rate using a series of transactions via a broker.”
When multiple exchange rates exist, US GAAP may permit the use of one of those exchange rates for remeasurement (per ASC 830-20-30-1, the “current rate of exchange”) and another for translation (per ASC 830-30-45-6, the “dividends remittance rate”). Thus spake the SEC staff on these provisions as they apply to Venezuelan operations:
“[T]he staff has recently become aware that… certain entities may have used the parallel rate to remeasure certain US dollar denominated balances that the Venezuelan subsidiary held and then subsequently translated the Venezuelan subsidiary’s assets, liabilities, and operations using the official rate. The effect of this accounting treatment resulted in reported balances in an entity’s financial statements that differed from their underlying US dollar denominated values.”
[For example,] assume that at a period end … a U.S. entity’s Venezuelan subsidiary held $10 million of cash denominated in U.S. dollars. Further assume that at the end of the period, the parallel rate was 5 Bolivars to every 1 U.S. dollar and the official rate was 2 Bolivars to every 1 U.S. dollar. Upon the remeasurement of the U.S. denominated cash to Bolivars and the subsequent translation of the Venezuelan subsidiary’s financial statements, an entity would have reported cash of $25 million for financial reporting purposes. [Italics supplied]
Finally, after 30 years of sitting on its hands, the SEC has acknowledged the insanity of using one rate for remeasurement and another for translation: among other crazy things, $10 million in cash is transformed to $25 million on the balance sheet—with a hefty income statement gain in the process (due to the declining VEB).
Unfortunately, though, the SEC’s solution is to soft pedal. If you’re in Venezuela, but nowhere else, kindly provide some additional disclosures. Everybody else: you can keep doing that thing you do with multiple exchange rates. To all you investors out there, take comfort in knowng that the EITF, staffed with your good friends from the Big Four, has this 30-year-old emerging issue on its agenda; they’ll know how to make things right—eventually.
I expect the SEC would respond that their longstanding policy is to stay away from overriding FASB rules until the Board has had its chance to fix a problem—no matter how insane and damaging those rules may be. My response is: that’s not even close to good enough. The feeling I’m left with is that the SEC, in ASU 2010-19, is conducting the orchestra with a wet noodle instead of a baton.
To help see why I think that the SEC’s response is inadequate, let’s try look at the problem from an auditor’s perspective; or stated another way, how an investor should have expected an auditor to have resolved these kinds of problems as they arose. Let’s imagine that an issuer shows the auditor the GAAP rules that lead to an actual $10 million in cash being reported as a fictitious $25 million; and the auditor perforce concludes that the issuer adhered to the letter of those rules. The auditor knows that the client’s balance sheet is materially misleading: is there nothing more to be done?
For the answer to that question, I refer to Interpretation 203-1 of the AICPA’s Code of Professional Conduct, Departures from Established Accounting Principles, which states as follows:
“[I]n the establishment of accounting principles it is difficult to anticipate all of the circumstances to which such principles might be applied. This rule therefore recognizes that upon occasion there may be unusual circumstances where the literal application of pronouncements on accounting principles would have the effect of rendering financial statements misleading. In such cases, the proper accounting treatment is that which will render the financial statements not misleading.” [italics supplied]
If Interpretation 203-1 is anything more than hot air, then surely it must be invoked by an auditor faced with the now-codified Venezuela fact pattern. Never happened and never will, you say? Conclusion: Interpretation 203-1 is hot air.
Surely, when looking to the FASB for accounting standards, the SEC must hold itself and the Board to a standard that meets or exceeds the minimum (albeit nominal) ethical responsibilities of CPAs. In applying those standards to ASU 2010-19, I can only conclude that once again, little more than hot air has been produced. If a GAAP rule fails to report dollars sitting in a bank account on the balance sheet according to their bank balances, that rule must be so arbitrary that it cannot be anything but misleading. I cringe at the fact that such a rule is referred to by people who should know better as “accounting.”
Chief Accountant Kroeker, I challenge you to find me an uglier wart in GAAP than this one. If you won’t act decisively, and with the integrity expected of all CPAs, to repair dysfunctional rules that materially misstate cash no less, then kindly explain to investors what exactly it is that you are doing.