Mary Schapiro needs constructive comments from the peanut gallery because this thing is a week old and since some people at the Commission have the attention of Tom Petters, they can’t afford to lose focus.
Just jump over the Public Comments page and let ‘er rip. Any section you want get down with your wonky financial reform knowledge is welcome.
It has not even been a week since the President signed the regulatory reform legislation into law, but at the SEC we are already working to fully implement the dozens of studies and rulemakings required of our agency,” said Chairman Schapiro. “We recognize that the process of establishing regulations works best when all stakeholders are engaged and contribute their combined talents and experiences. We look forward to preliminary public comments in these areas.
Not only that! The SEC needs more people. This 2,000-some odd page behemoth is putting asses in cubes and more of the kicking ass and taking names will be had. Just two ways you can join the good times going on at the SEC.
Just last week we mentioned the American Bankers Association and its efforts to undermine the FASB’s latest fair value proposal that, in the ABA’s mind, could bring down civilization as we know it.
Because of this danger, the ABA encouraged “investors” through email and on its website to write individual letters to the FASB, expressing their displeasure with the worst idea in the modern history of double-entry accounting. We say “investors” because the ABA not-so-subtly asked everyone (i.e. who felt the overwhelming urge to write Bob Herz & Co.) to refer to themselves as such.
Further, the ABA provided a template of a letter to send to the Board for the “investors,” however, it did warn to resist using the example as their own because A) this is far too important and telling the FASB that fair value pains you in the deepness of your soul and takes food out of your children’s mouths will be a far more effective narrative; and B) the FASB hates form letters. HATES. So much so that Bob Herz rips up all his gold stars that he gives for the constructive letters he receives and thenyour unoriginal ass gets negative points.
The group urges investors to “write your own letter — the FASB does not appreciate ‘form’ letters, and often discounts them in their analyses.”
Simple enough, right? Well, maybe. But In his column today, Jonathan Weil gives an example of one ABA soldier that wasn’t very good at following instructions:
Among the letter writers was Terry L. Stevens of Francesville, Indiana, who identified himself as a bank investor, as the ABA had suggested. He didn’t mention that he also is chief financial officer and executive vice president of Alliance Bank, a closely held lender in Francesville with $270 million of assets.
“As a bank investor, of utmost importance to me regarding the banks in which I own stock is their financial position, and transparent financial reporting is key in order for me to make investment decisions,” Stevens’ letter said. “With this in mind, I am writing to express my deep concerns and opposition to the portion of the proposal that requires all financial instruments to be marked to market.”
Stevens didn’t write those words himself. He copied them verbatim from a sample letter the ABA posted on its Web page. So, too, did a bunch of other bankers who submitted comment letters to the FASB opposing its proposal, notwithstanding the ABA’s warning that they shouldn’t do cut-and-paste jobs.
This had to be a mistake, right? This is far too important of an issue to the banks of this country that a mishap like this could just happen. Bankers are responsible people that take this stuff very seriously and would never risk going through the motions just to serve at the whims of their lobby’s voice…would they?
Stevens told me he didn’t have time to write his own letter from scratch. “The points that I grabbed out of their paragraphs did a good job of explaining how I felt about the situation,” he said.
As you may have heard, there is a number of mighty upset people occupying various streets around the country. By reading some of the signs being held by these occupants, it’s obvious they’re peeved about a number of things. With such a wide range of gripes, the crowds have gotten quite large and since many people sympathize with the protestors, lots of donations are being made by those passing by, usually in the form of cash. This, as any accountant worth their salt knows, can be problematic, as evidenced by this video:
As the protests have grown, so have the donations. And since protests aren’t exactly bastions of internal controls, the problem of tracking the money coming in and being spent has become quite a chore. That chore has fallen on one person named Victoria Sobel who is functioning as Occupy Wall Street’s “chief treasurer.”
There’s no indication that Victoria is an accountant and, oddly enough, there doesn’t seem to be a lot of ready accountants amongst the occupiers, so the methods currently being used aren’t exactly robust. They started housing collections using “a large cooking pot covered in cardboard and duct tape” and gradually moved towards high-tech tools such as “donation buckets” and “a yellow messenger bag.” Despite these improvements, this system still needs some work Fortunately for Ms. Sobel, a person with some relevant experience recently turned up:
Then the first consultant, a certified public accountant sympathetic to the cause, came to help. Jo Ann Fleming […], who besides her accounting work has a radio show called Flash Talks Cash, sat down in a red tailgating chair next to three activists volunteering on the Occupy Wall Street finance committee.
Fleming heard a rundown of how the operation is working so far: Most of the money comes in through two donation buckets stationed at the ends of the park, where a steady throng of tourists and commuters is always passing by.
Teams of volunteers are split up into working groups for areas like food, sanitation and medical supplies, then spend the money on communal goods. Anyone who wants to be reimbursed for expenses has to get approval from a finance committee member before making a purchase. If it’s less than $100, they’ll sign out some cash, with orders to return with the goods and the receipt. If it’s more than $100, the purchase is supposed to be approved at a town meeting.
Once again, a CPA to the rescue! But since Ms. Fleming can’t quit her day job, she gave the best advice she could to the team on the ground:
After some probing, accountant Fleming determined the group needs to come up with a clear policy on how to get reimbursed for expenses. She suggested more frequent collection of the donation buckets, to avoid the temptation of dipping hands in—“cash is very troublesome.” And she urged them to create a spreadsheet tracking how much was received and paid.
More frequent collections. Clear, common sense policies. Spreadsheets. All excellent suggestions. But perhaps most importantly, Ms. Fleming recognizes when someone is doing the job of three people and is on the brink of cracking up (an important instinct in today’s accounting firms) so she gave Victoria some advice.
She turned to Sobel: “One woman can’t run the show. You’re exhausted; I can hear it in your voice. You need to delegate. You’re going to get burned out.”
Any double-entry experts that have some time on their hands and want to help the cause need to get downtown ASAP.
