The Big “Regulation” Joke

laughing.jpgEditor’s Note: Want more JDA? You can see all of her posts for GC here, her blog here and stalk her on Twitter.
In an uncharacteristic move by one of our favorite accounting professors, Prof Albrecht went off on regulation over at The Summa yesterday and personally, JDA was stoked.
The Economic and Regulatory Shadow is recommended in its entirety but here’s a juicy tidbit for you to suck on:

It is frustrating to be an accounting professor and to live in the United States of America. A mind set that triumphs the interests of corporations and auditors over those of investors is entrenched in the regulatory shadow. Consequently, any policies that might favor populist policies have little chance of success.


The federal government’s financial and economic regulatory apparatus is comprised of the Treasury Department (Treasury), the Federal Reserve (Fed), and the Securities and Exchange Commission (SEC). The top positions are political appointees, but the bulk of the work is performed by career and long-term personnel. It is a lot like the situation at the State Department (State), Department of Defense (DoD), and the National Security Agency (NSA).

Know what’s really funny about Professor Albrecht’s timing? The Fed is facing this same regulatory dilemma, even if major financial bloggers missed the point over the weekend. Sure, they care about the spectre of an audit but mostly right now they don’t want the President being the one who puts regional Fed presidents in their positions. I don’t blame them for tripping on that.
So? Our dear Professor has gone out on one hell of a limb here, nearly unheard of when it comes to accounting professionals. The glossy marketing materials CPAs outnumber those who keep it real like Francine, Dennis, Skeptical CPA, and now Professor Albrecht but we’re making progress (he did always get the IFRS thing so this isn’t really all that surprising of a position).
I’m constantly thrilled to see outrage. Maybe that’s because I’m a shit-disturber but I think it is about time the industry get worked into a lather over perceived imbalances in the very regulatory system that we have to tip-toe around. All that tedious stuff you little CPAs do each and every day? It means nothing without the backbone of a regulatory system and as Professor Albrecht so astutely points out, we are sort of lacking in that department these days.
And? WTF are we supposed to do about that? Heads down and keep ticking and tying, kids, there’s not much else to do at this point.

>75: That Time of Year Again: Balancing the Exam and Busy Season

Help!.jpgEditor’s note: This is the latest edition of >75, our weekly post on questions that you have related to the CPA Exam. Send your questions to tips@goingconcern.com and we’ll do our best to answer as many of them as possible. You can see all of the JDA’s posts for GC here and all our posts related to the CPA Exam here.
Do you have a CPA exam question for >75? Send it in. I’ll be nice I swear. Possibly useful.
So it’s January and some of you are heading into a rough couple of months. With the 18 month clock ticking on the CPA exam, you don’t really have any options but to fight through it. Or argue with people on the Internet. Maybe that’s why you don’t have enough time to study?
Anyway. It’s not easy but remember it is also temporary so as long as you suffer through it a bit (oh please, is it really that bad?), it’s possible. Here are some things I’ve seen work:
Talking to management and partners – I know. You’re going to laugh me out of here (“wtf version of JDA is this?”) but stick with me. Have you asked? I’m not saying this is always a successful method but it can never hurt to ask or let management know you’re taking the CPA exam. Especially if you work in a smaller firm, just talk to someone above you with some pull. I’ve seen it so I know it isn’t impossible.


Cutting out the extraneous crap – You know exactly what I mean. Time management for studying is a lot like budgeting for chronic spenders. I used to burn through paychecks until I actually printed out three months worth of debit and ATM charges and saw how I was $2 and $7 and $14ing my way to $0 in no time. In much the same way, you have to figure out where you are spending your time in a week (or a day if that works better for you). Things that take “a few minutes” (Facebook anyone?) add up so count them.
Not doing too much – One exam is enough if you really are swamped. It’s fine. Just don’t let post April 15th suddenly turn into late August because you were “so wiped out” from busy season. Take a realistic break but don’t get too detached from your goal.
What works for you to get through busy season and the exam? And don’t say trolling accounting websites trying to pick Internet fights.
Good luck? As always, it has nothing to do with circumstance, it’s just discipline.

The FDIC’s New “Risk-Based” Fee Policy. Or, Alternatively, “F&%k You, Pay Me; Banker Edition”

Uncle Sam.jpgEditor’s Note: Want more JDA? You can see all of her posts for GC here, her blog here and stalk her on Twitter.
Listen, we know the FDIC is broke, there’s no use pretending they aren’t. But apparently we’re going to keep doing it so let’s stop for a moment and analyze the FDIC’s latest crackpot scheme to keep bad banks afloat and their balance in the black, shall we?
The summation up to now — for those of you with short attention spans — is that the FDIC is looking to tax banks’ asses based on the risks they take. On the surface that doesn’t sound like a bad idea until you consider the fact that the FDIC, by its very nature as a “safety net”, encourages the exact behavior they’re looking to “penalize”. Keeping in mind also that the Obama administration is coming down on banks from the other end with some tax scheme, it makes you wonder why the hell we bailed them out in the first place.


Blame the academics and these brainiacs in Washington who believe there’s nothing wrong with the fundamental framework of American banking, least of all that any of it could possibly be attributed to the attitude that Uncle Sam will always come to banks’ rescue. Here’s hoping the bankers paid attention in Econ 101 when they went over that whole “no such thing as a free lunch” part.
UPI:

FDIC Chairman Sheila Bair said there was “a broad consensus of academic studies,” that concluded “poorly designed compensation structures can misalign incentives and induce risk taking.”
Bair said called a study of “compensation structure, rather than levels of compensation,” a fair approach.

Maybe I just don’t have the auditor mind needed to wrap around a concept like this but WTF is that supposed to mean?! The FDIC epitomizes moral hazard so how in the hell is it that the FDIC is the one coming in to tap banks to cover said risks? I’m not rationalizing banks’ behavior (I remind dear reader here that the top 5 banks in America hold $275 trillion in notional derivative exposure) but, uh, just because Sheila needs to cover the next round of failed banks doesn’t make it appropriate to start regulating now.
Has she ever heard of too little too late? How about too much too late?
As I have already pointed out, we all know who is going to ultimately pay for this and it sure as hell isn’t the banks. Bend over, the next round is about to hit and it’ll hurt less if you’re prepared.

Double-dipping the Economic “Recovery”

Thumbnail image for tax man.jpgIn case you haven’t heard, it’s go time for the Obama administration to cover its continually-growing deficit with no sign of increased foreign investor demand for unstable and uncertain US debt. What happened to passing a health care overhaul before Christmas? And what about those 140 failed banks in 2009? And hey! What became of that $700 billion in stimulus money that was supposed to save and create bazillions of jobs?
Here’s the solution. Tax their asses.
NYT:

President Obama will try to recoup for taxpayers as much as $120 billion of the money spent to bail out the financial system, most likely through a tax on large banks, administration and Congressional officials said Monday.


In a desperate scramble to come up for cash, the administration has thrown out a couple of unpopular ideas (unpopular if you’re a banker, of course) including excessive taxes on bonuses and bizarre financial transaction taxes. Like squeezing blood from turnips, apparently these guys forget that it was less than a year and a half ago that Hank Paulson appeared on the Hill threatening full-on financial doomsday were TARP not instituted rightf*ckingnow. So much for pulling out the bazooka in his pocket.
And let us not forget that shit rolls down hill. Who do you think would ultimately be responsible for these additional monies? The banks or the idiot customers who continue to shovel out ever-increasing fees to said banks? Exactly.

Lobbyists for bankers, taken by surprise, immediately objected to any new tax. They said financial institutions had been repaying their portion of the bailout money in full, with interest. Losses from the $700 billion bailout fund — estimated to run as high as $120 billion — are expected to come from the automobile companies and their finance arms, the insurance giant American International Group and programs to avert home foreclosures, and the president is aiming to recoup that money.

I really, really hate to side with the bankers here but they are absolutely right. If retribution for the financial crisis is our goal, taxing them to death isn’t the way to achieve that. If paying our government’s bills is the goal, however, I could see how this could easily be spun into populist payback for the pain and suffering of the last 2 years.
Hate to break it to you, America, but any money potentially recouped by this genius scheme has already been spent and certainly wouldn’t result in any long term benefit to us as a country. I’d use the pay day loan analogy again but hell, isn’t it played out by now?

>75: Procrastination

Procrastinate.jpgEditor’s note: This is the latest edition of >75, our weekly post on questions that you have related to the CPA Exam. Send your questions to tips@goingconcern.com and we’ll do our best to answer as many of them as possible. You can see all of the JDA’s posts for GC here and all our posts related to the CPA Exam here.
First of all, I have to give it to all of you little future CPAs of America, you REALLY know how to put things off until the last minute, don’t you?
I’m going to let you in on a tiny little secret: the exam never goes away.
Let me paint an “imaginary” scenario where CPA Review classes are starting in less than 48 hours. Classes have been on hold for over two months and suddenly, within this 48 hour period, there is a rush of panicked CPA exam candidates realizing they’ve got less than a day left to figure out a plan. Anyone else see what’s wrong with this picture?
I’m not talking about a handful of people, I’m talking about a significant chunk of you. You know who you are and you know exactly what I’m talking about.


So what is it? Do you believe that the exam will pass itself? Or if you put it off long enough somehow you’ll wake up one day a CPA? I hate to break it to you but that’s really moronic.
There are students in our classes that are 50-some years old. Think about that. They graduated 30 years ago and are STILL putting this stupid ass exam off. So don’t think you’re some hero of procrastination just because you let 18 months go by and started losing exam scores, you aren’t special.
The bottom line is this: it is all about what you want to do with your life. Do you really want to be a CPA? Then you’ll suck it up and finish. Don’t do it because your parents want it or your girlfriend wants it or it’s your grandma’s dying wish. You are only setting yourself up for a life of half-assed failure, misery, and disappointment.
Which is kind of like what you’re setting yourself up for with a CPA and a career in public accounting except + tchotchkes. Win* (I think).
Point is, stop. In the time it takes for you to come up with 1000 excuses, you could have already booked your exam and gotten through at least 150 MCQ. Yes, it sucks but guess what? You picked it. You can make it worse on yourself and be that 50 year old guy in the back of our Live class or you can just get through it and stop bitching.
/end rant. Do it.
*I’m obligated to say that because of my day job

The Fed on Glass-Steagall; Me on STFU, Fed Boys, We Got This

Thumbnail image for Solutions.jpgKansas City Federal Reserve President Thomas Hoenig is a voting member of the FOMC this year and apparently he got my note.
He is charging into the year as a cheerleader of long-dead regulation and ending TBTF. This is a song and dance we’ve seen from the Fed about a bazillion times now. Just because regulation is my shit doesn’t mean I’m entertained in the least by this.


WSJ:

A top U.S. Federal Reserve official said Tuesday it’s necessary to consider how banks considered too big to fail can be broken up so they no longer pose a systemic risk to the U.S. economy.
“Beginning to break them, to dismember them, is a fair thing to consider,” Federal Reserve Bank of Kansas City President Thomas Hoenig told a panel at the annual meeting of the American Economics Association.

Well if insisting too big to fail is too big to continue isn’t enough, maybe Hoenig’s declaration of “bring back Glass-Steagall!” will make the panties drop?
Nope.

“We’ve got to start somewhere — and size matters,” Hoening said, calling for rules to address the problem that are simple and easy to enforce.
“We’ve got to strike while the iron is hot … but we must also do it right,” Hoenig said, adding there was a “chance” that new rules could be passed this year.

I’m going to go ahead and resist the easy joke here.
So? Should commercial banking and investment banking once again be absolutely distinct from each other?
I think if we’ve learned anything from this crisis it’s that the lines are blurred; accountants should know finance, finance professionals should know accounting and Christ, no one let the quants near the securitization models again. I have seen a noticeable increase in bankers, CFOs, etc pursuing CPA licensure since 2007. I can’t tell you numbers (if I did I’d be making them up) but a lot more of them call and the line is no longer as definitive as it was.
Our rules need to change. It’s not that we should bring back Glass-Steagall, it’s that two new guys need to write one hell of a regulatory bill that redefines our financial system as we know it and slap their names on it.
The financial system we’ve got sucks and if we don’t do that, Fed guys like this will keep yammering on about interest rates they never plan to raise and popping future bubbles.

Apparently the Fed Needs More Money

Thumbnail image for PiggyBank_broken.jpgEditor’s Note: Want more JDA? You can see all of her posts for GC here, her blog here and stalk her on Twitter.
I know, the headline stunned me when I read it the first time too. First via James Turk, I had to stop and look at that for a second. Don’t they make it? How could they possibly need it?
Initially, the Fed called this proposed deposit facility a component of its “exit strategy” (the existence of which, much like Sasquatch, is still up for debate), insisting that by creating an interest-bearing drain for banks’ funds held at the Fed, it could clear out some of the money sloshing around in the system.


Although they also believe asset sales to be an option, I’m still not sure who the hell they are expecting to buy these bonds (unless they’re willing to take a loss, and knowing the Fed that’s not too likely) so stay tuned.
I believed this whole interest-bearing deposit facility nonsense was really just a Bad Bank for Dirty Fed money but it’s actually the Fed begging for deposits, so I guess I was wrong. But why, then, would they paint this as an exit strategy?
From the Turk piece:

The US government needs ‘deposit currency’ – or ‘electronic’ currency, to put it into Mr. Bernanke’s terms – so that it can pay its bills by check or wire transfer. Payment for goods and services by deposit currency are made through the banking system, and nearly all commerce in the United States is conducted in this way. So where will the Federal Reserve get enough deposit currency to enable it to continue purchasing US government debt?

In 2008, “public debt” was considered to be $9.9 trillion dollars or 70.2% of GDP. By 2009, that number had ballooned to over $12.9 trillion dollars, nearly 91% of GDP. Even more disconcerting? This is using governmental accounting rules which — as any of you who have ever worked in government can attest to — don’t necessarily coincide with GAAP logic.
Let’s not forget that a large chunk of this debt is owed to the Fed itself (for some reason) perhaps because inflation isn’t bad enough and we somehow should pay them more for the convenience of having printed money and payment systems.
I’m not 100% on what’s going on here but it’s beginning to look awfully suspicious.

>75’s Year in (CPA) Review

Thumbnail image for confidence.jpgShameless self promotion: JDA also did a Year in Review and I tried really hard to keep the accounting crap out of it.
Anyway, on to the CPA exam. We’re heading into the last day of the year and I have got to say, you bastards have me overdosing on Red Bull just to keep up. I’m not sure what happened this year but it feels like a lot of you got fed up with dragging your asses along on this exam. Or maybe you got laid off and all the sudden had a whole bunch of time to study. I’m guessing a lot of you finally realized for the first time in your careers that you can’t coast forever.
I talked to a lot of you this year. A LOT. So many that I’m about ready to crawl into bed for the next 72 hours (after we make the last day of the year, of course) and hibernate. Where did all of you come from? Why now?


Whatever inspired this surge in interest in those three letters, I have to say I saw a lot of inspirational shit go down in CPA exam land. Like the guy with a learning disability who finished in a year using both a full review and a supplement each time. Guess what? CPA. Or the student who put this off for so long she couldn’t believe she was that old sitting in that chair taking that test she’d dreaded for 15 years since college. She failed miserably the first time around, walking in there convinced she would.
The Self Fulfilling Prophesy candidate probably makes up 15% of our student base (I’m making that number up) and takes a little extra encouragement to pass. The second time around, she went in there and got through the exams. Now she just needs to find a job.
And that’s our other student. My Firm is Paying for This guy doesn’t realize that there’s no such thing as a free lunch, nor that there’s a bonus in it for him if he can just pass. Hell, they bought his ticket in. But they also worked him into the ground and he never studied on account of always being “too busy”. He’s got lots of time to study now that he’s laid off but his materials are outdated and useless. Too bad.
Wherever they come from, whomever pays for them to get there, this was sort of the year for the CPA exam. Or maybe the AICPA just scared everyone shitless with that IFRS threat and that’s why everyone is scrambling to take this exam and get it over with. Whatever works, I’m okay with it. I keep a case of Red Bull under the sink in the office.

How Bad Unemployment Is Guaranteed to Get Worse

Flush_hope.jpgEditor’s Note: Want more JDA? You can see all of her posts for GC here, her blog here and stalk her on Twitter.
I try most of the time not to jerk myself off but this is important and worth paying attention to. Until the grand money laundering scheme is finally put out of commission, economic “recovery” will continue to drag, unemployment will continue to rise and credit will remain tight.
So check out “How a Jobless ‘Recovery’ Costs You… Quietly” for more on the plan to print our way out of this mess. Sort of like Enron after Ken Lay’s convenient death, it’s obvious what’s been going on once you realize the details are painfully simple.
Anyway, the strategy moving forward into 2010 will be one of cautious optimism. Hell, calling it optimism is pushing it.


Business Week (Why This Business Owner Isn’t Hiring in 2010):

Right now the Administration is proposing income taxes that are still equivalent to the rates during the Clinton era. I’m not sure how long this is going to last before the rates start going up. And I’m reading that many states are quietly raising their unemployment taxes. Some experts are estimating that state unemployment taxes could double or even triple in the next year or two. Is an increase in the Federal Unemployment Tax rate on the horizon? One expert thinks so.

Read that again just to make sure it sinks in. Increased unemployment taxes is bad enough a phrase on its own but add the words “double” and “triple” and suddenly you see small business walking blindly into the train tunnel with the 5p Bridge and Tunnel Express coming straight for it.
AccountingWeb reported the potential increase on December 17:

States that have borrowed money from the federal government under the Federal Unemployment Trust Act (FUTA) to cover their current obligations will need to pay this money back with interest.
According to the Journal of State Taxation, at least 12 states, including Michigan, Texas, and Virginia, with depleted trust fund balances had borrowed from the federal government under FUTA provisions of by the end of the summer, and others are expected to follow suit. States that accepted interest-free loans offered under ARRA (the Stimulus Act) will need to pay interest on these loans after two years.

There’s probably some really offensive translation of the FUTA acronym I’m missing here but frankly I’m just tired of having to report on this depressing shit. Looks like another exciting year ahead! Yay!

Pleasing the Accountants, Road Trip Style

Receipts.jpgEditor’s Note: Want more JDA? You can see all of her posts for GC here, her blog here and stalk her on Twitter.
NYT had a piece yesterday called “Paying With Plastic to Please the Accountants” and I have to admit at first glance, the title annoyed the shit out of me. The accountants don’t care what you use when expensing your stupid airport Starbucks and car rentals, all they want is to be left alone to decode your receipts in peace. At least mine does.
But it isn’t just the accountants. Apparently your expenses are of extra importance to the IRS – though we’ll save the wild speculation that might dictate Timmy the Tax Cheat is just really hard up for some revenues (especially after that $38 billion tax break he gave Citigroup without anyone’s permission).

The I.R.S. is engaged in an initiative to audit tax returns of about 6,000 companies, partly to look at executive fringe benefits, including travel-expense procedures. This takes place as companies are already struggling to get a better handle on overall travel and entertainment management, especially as business travel picks up in a still shaky economic environment.

The article goes on to talk about extra airline fees (I won’t bitch about the $40 I just had to pay to check a suitcase on a recent Chicago trip) and makes expense reports sound like financial statements. The IRS apparently doesn’t care about receipts for charges under $75 while most companies use $25 as their receipt required limit. Is a $4 airport latté material? Maybe not. Are 25 dinners between $20 and $24? You bet your sweet little bean-counting ass.
I will go ahead and state the obvious here because sometimes I feel like you rubes need a BIG SIGN: in this economy, companies can no longer afford the jetsetting of yore, and why the hell should they? With video conferencing, email, mobile productivity and social networking helping to bring an entirely new meaning to collaboration, all of that cross country crap is no longer as critical as it once was. And so go the $4 airport lattés and bad $15 dinner tabs with it.
So remember, kids, keep your receipts, Timmy might want to run some substantive tests on your company rental cars and client dinners on the road. God forbid he not get a piece.

UK Financial Reporting Watchdog: ‘We don’t need no Big 5’

Solutions.jpgEditor’s Note: Want more JDA? You can see all of her posts for GC here, her blog here and stalk her on Twitter.
Once upon a time, there were 8. And then 7. And then 6. And then 5. And now 4. I’ve thrown out the idea of a large audit failure sending one of the Big 4 tumbling but the idea has been met with resistance; and naturally so, they’ve survived this long, right?


Accountancy Age:

Stephen Haddrill, the new Financial Reporting Council chief executive, in his first interview since taking the post, said there was little chance a global challenge to the Big Four – PricewaterhouseCoopers, Ernst & Young, Deloitte and KPMG – would emerge in the near future.
“I don’t think it is achievable in the near term and the priority for us has to be that we are prepared for the worst and that is where I will put my focus,” he said.

To read the rest of Haddrill’s interview with Accountacy Age, one might be inclined to point out that the guy is only a little bit pessimistic and for good reason. The Big 4 cannot exist indefinitely as they have, deflecting fines each time they bumble a big audit. It isn’t a problem exclusive to the UK and in fact, the Big 4 might not realize it but they are fighting the battle to save American capitalism. To that end, sacrifices may be required in the name of “competition”, whether or not the Big 4 are ready to embrace the idea.
They call them the Final Four because it is widely believed that the large accounting firms cannot lose another player but what’s to stop regulators — either Internationally or here at home — from busting down the joint and shutting one down? Anyone forgotten Satyam?
The firms — clever Trevors that they are — already know regulators are on their asses and behave accordingly. Crossing their Ts and dotting their Is, it was incredibly easy for PwC to say “Satyam wasn’t our problem” here in the states just as they’d have done if it had gone down in the UK, Dubai, China… it doesn’t matter, that’s what the lawyers get paid for.
Anyone get the feeling we’ve got a problem on our hands or is that just me? “Preparing for the worst” eh? Sounds like a plan.

>75: I’ve Passed, So What About CPE Requirements?

CPE.jpgEditor’s note: This is the latest edition of >75, our weekly post on questions that you have related to the CPA Exam. Send your questions to tips@goingconcern.com and we’ll do our best to answer as many of them as possible. You can see all of the JDA’s posts for GC here and all our posts related to the CPA Exam here.
Reader Kyle (Louisiana CPA applicant) asks:

Passed the exam in October, start working part-time (finishing useless grad school till August) in January. Do I have to start doing CPE stuff even though I won’t be a “CPA” for at least a year? Can I start doing CPE stuff now and have it count? Does taking the CFA count as CPE stuff?


As a general rule (since each state/territory makes its own CPA exam rules), CFA, CA, MBA, STFU, whatever letters you have after your name before tackling the CPA mean shit to most state boards of accountancy. However, maybe your CFA required classes that will also meet your state’s CPA exam requirements, figure it out independently of whatever other certification you have and give up the idea that you get credit for any of that.
You can see more about the Louisiana requirements here (or find your state here). I hate the word “expert” and I don’t like having to claim that I am one just because I work with this every day in CPA Review. So when in doubt, check directly with your state board or NASBA. Be patient and make a list of questions you have for them – I don’t feel sorry for you if you go into this blind and then cry to me that you had no idea you shouldn’t pay for all four parts on your NTS. All you had to do was ask and someone who knows would have told you. /endrant, I’m just suggesting to also contact the Board or NASBA.
That being said, Louisiana doesn’t specifically define “CPE” but they don’t really have to. Generally you can speak with your state’s society of CPAs to get information on accepted CPE programs in your state. Again, there are resources available to you as a CPA candidate, it’s up to you to utilize them.
Our candidate also asked about experience requirements, which Louisiana defines as the following:

At least one year of experience must be confirmed that was within the four years preceding the date of this application; involved the use of accounting, attest, management advisory, financial advisory, tax, or consulting skills; and, was supervised and verified by a licensee.

It only takes 18 months (or less) to get through the exam, you can do the math, little future CPA.
Like I said, you are encouraged to send your CPA exam questions to us but do your own homework, I’m probably hungover while writing this.