The Federal Reserve

There Was One Wreck Paul Volcker Couldn’t Salvage

The out-pouring of encomia for Paul Volcker, who has died at age 92, would tower over even his own formidable 6 ft. 7 in. (e.g., samples in the Financial Times and the New York Times). His credits over more than 40 years include the taming of the rampant inflation of the 1980s as Federal Reserve chairman and, post the […]

Does Anyone Want to Work for the Federal Reserve?

With Caleb way way out of town, I’m finally able to talk about the Fed. In this case, I figured I’d make it useful for those of you looking for non Big 4 careers but unsure where to start.

The Fed has money. Your salary, were you to use your accounting degree to work there, would come out of the money they allegedly return to Treasury each year as “profit,” so they can pretty much make up any number. A luxury Uncle Ernie just doesn’t have.

This is just my personal experience (having dated an accountant who worked at the SF Fed in a former life), to qualify you probably have to have a sick attention to detail (I won’t go so far as to use the word anal but you get it), enjoy a rigid schedule (he would get up at 3 in the morning every work day) and possibly play too much WoW (self-explanatory). I know several of you who read this site that completely fit that bill, so read on and see if you want to get on this sweet money gravy train:

As the central bank of the United States, the Federal Reserve’s mission is to provide the nation with a safer, more flexible, and more stable monetary and financial system. For us to succeed in meeting this public mandate, we depend on the expertise, judgment, integrity, and dedication of employees with various skills, backgrounds, and training. As a Federal Reserve staff member, you will play a critical role in accomplishing this mission.

You can finally use your Masters for something useful in exciting areas like Financial Analyst/Bank Examiner, Bank Supervision and Regulation, or Consumer and Community Affairs.

Individuals interested in a career as an analyst should have a degree in business administration with concentration in accounting or finance, and experience in financial analysis as it relates to banking. Knowledge of the laws and regulations governing banks and bank holding companies is preferred. A master’s degree is required for most higher-level positions.

That’s at the Board, where they still have to pretend to be government. But the regional banks need number-crunchers too, so if you are in Atlanta, Boston, Chicago, Cleveland, Dallas, Kansas City, Minneapolis, New York, Philadelphia, Richmond, San Francisco or St. Louis, check with your local regional Fed bank to see what’s available. There are also smaller branches in places like Salt Lake City, Portland, Baltimore and Houston, they may need some warm bodies to count the beans or supervise said counting of beans.

The New York Fed in particular has some exciting openings in Financial Institution Supervision and Audit worth checking out if you’re close or considering a move to that market.

Here’s a decent (if slightly outdated) report on Fed bank pay to give you a general idea what they’re working with. According to Glassdoor, a Senior Accountant at the Boston Fed makes around $70k, although from what I’ve read from others, starting pay at the Fed is significantly lower than Big 4 starting salaries in comparable markets.

Any takers?

The Fed’s Financial Accounting Is a Beautiful Thing

Controllers, don’t you wish you had this sort of authority? Imagine writing your own financial accounting handbook (forget GAAP, it doesn’t apply here!), plugging your financial statements with all the footnotes you want and rewriting the rules in the middle of the reporting season just because you feel like it and, maybe in this case, because it will paint a rosier picture of your financial condition.

Wouldn’t it be great if we could do this with our checking accounts? You could just take the money that is owed to others (let’s call “bills” “negative liabilities” instead, even though in strictly technical terms a negative liability would be an asset, which we know bills are not) and change its name, give it a new presentation and VOILA! Instant solvency!

On January 6th, they tried to sneak a little change in presentation that, for now, doesn’t really matter but might when interest rates skyrocket and they are no longer handing out huge amounts of “profits” to the Treasury. Read:

Effective January 1, 2011, as a result of the accounting policy change, on a daily basis each Federal Reserve Bank will adjust the balance in its surplus account to equate surplus with capital paid-in and, in addition, will adjust its liability for the distribution of residual earnings to the U.S. Treasury. Previously these adjustments were made only at year-end. Adjusting the surplus account balance and the liability for the distribution of residual earnings to the U.S. Treasury is consistent with the existing requirement for daily accrual of many other items that appear in the Board’s H.4.1 statistical release. The liability for the distribution of residual earnings to the U.S. Treasury will be reported as “Interest on Federal Reserve notes due to U.S. Treasury” on table 10. Previously, the amount necessary to equate surplus with capital paid-in and the amount of the liability for the distribution of residual earnings to the U.S. Treasury were included in “Other capital accounts” in table 9 and in “Other capital” in table 10.

So instead of counting up the amazing Fed profits to the Treasury every year like they’ve done for as long as we can remember (and lately with lots of huge fanfare and fireworks, including the last record $78.4 billion), they’ll be readjusting the numbers on a weekly basis. Why they feel this is appropriate is beyond my analytical ability but should anyone have some insight, I’d love to hear it.

In the meantime, I guess it is reassuring to know that accounting tricks or not, the Fed can’t possibly be insolvent.

Accounting News Roundup: UBS Clients Have ‘Mere Hours’ to Come Clean; Dixon Hughes Sued for ‘Comfort Report’; “Big 4 Only” Bank Covenants – Revealed! | 06.18.10

UBS Customers May Have `Mere Hours’ to Report to IRS [Bloomberg]
Since the Swiss Parliament were finally able to give the OK on the agreement to disclose UBS client names to the U.S., it’s only a matter of time until the IRS starts kicking down doors in the middle of the night.

“For UBS account holders, they have mere hours to run to the IRS and hope they can disclose the account before the Swiss hand the data over,” said Asher Rubinstein, a partner at Rubinstein & Rubinstein LLP in New York who said he’s been “getting panicked calls all week.”

The lesson to be learned here, it appears, is that he IRS on a bluff, you are likely to be wrong, wrong, wrong. Doug Shulman doesn’t like to be take for a fool, “We will immediately follow up on the information we receive from the Swiss and we will vigorously enforce the laws against those who have attempted to evade their tax responsibilities by hiding their assets offshore.”


KPMG chief calls for audit reform [Accountancy Age]
John Griffith-Jones, who wishes everyone would get comfortable with the idea of the Big 4, does admit that the question about the purpose of audit is a legit one that should not be ignored, “What is the point, they and others ask, of doing extensive and increasingly elaborate audits of the financial accounts of our banks, when audits failed to identify the huge and systemic risks which led to the near collapse of the Global banking system in the Autumn of 2008?”

Campbell Recalls SpaghettiOs [WSJ]
UH OH…

600 Parish investors sue accounting firm [Charleston Post Courier]
Dixon Hughes is being sued by 600 investors of convicted mini-Madoff Al Parish for their “Comfort Report.” “The lawsuit alleges that the firm claimed to compile the report from brokerage statements, when it received statements generated only by Parish that ‘summarized imaginary account balances.’ ” Oops.

Oh, You Mean Like the Same Fed Audits We Already Have? Way to Go, Congress! [JDA]
“As any accountant will tell you, we perform audits each year to ensure the comparability of financial statements for the sake of investors. Since there is no comparing Fed statements and there are no investors (excluding the banks with mandated stock holdings in the Fed banks they are regulated by), basically all we’re doing is jerking off with our left hands pretending it is someone else doing the jerking.”

Firing squad execution sobering, but dramatic [AP]
And who doesn’t like drama?

Restrictive bank covenants keep the Big Four on top [Accountancy Age]
“Big 4 only covenants” in lending agreements are blackballing smaller firms according to BDO International CEO Jeremy Newman and others. Nonsense, you say? AA presented an example:

Buried in the 81-page credit agreement for US-based healthcare provider Amedisys is a 22-word stipulation that highlights a problem some fear is threatening the stability of the global economic system.

“Audited consolidated balance sheets of the group members… [must be] reported on by and accompanied by an unqualified report from a Big Four accounting firm,” the phrase reads.

There’s no telling how many loan agreements have this exact language but “Big Four” is often replaced by “reputable” so it’s not if the “Big 4 covenant” is cooked right into the template. That being said, AA reports that the Big 4 + GT and BDO admitted last month that the covenants do exist in the UK.

Strangely enough, Amedisys is currently in the cross-hairs of Crooked CFO-turned-Forensic sleuth Sam Antar.

CFOs on vacation: Fewer call office [San Francisco Business Times]
God forbid.

The Fed’s Report on Small Business and Credit Card Reform Fails to Impress

This story is republished from CFOZone, where you’ll find news, analysis and professional networking tools for finance executives.

When Congress voted not to cover small businesses under the credit card reform bill last year, they asked the Federal Reserve to study the issue and report back in May. A few weeks late, the Fed recently came out with its report.

Those who support not giving small businesses with 50 or fewer employees the same protections provided to consumers claim the findings support their view.

But the real bottom line is this: The findings aren’t conclusive either way.


That’s not to say the report doesn’t present a few definite opinions about the Credit Card Accountability Responsibility and Disclosure Act. (Yes, the acronym is CARD).

For example, it supports extending the standardization of disclosure rules about account terms to small business, saying it would help companies compare credit card plan costs.

It also opposes limiting bank’s ability to adjust interest rates. The thinking is that it’s more difficult for banks to assess the riskiness of small business borrowers than consumers. Plus small companies tend to need more credit. As a result, curbing the ability to raise rates “may lead to higher initial interest rates, which would harm those firms that borrow on small-business credit cards.”

So that sounds pretty definitive. It isn’t. The bill provides “substantive” protections against certain practices, from raising interest rates to charging penalties. But, the report barely touches on the rest of the bill, such as provisions that limit fees and the ability to tinker with payment deadlines.

Perhaps, in a rush to meet their deadline, or not miss it too badly, the Fed simply didn’t have time to get to the rest of the bill. But it means that they failed to provide a conclusive, comprehensive direction to Congress.

And by focusing on just one or two provisions, they created the false impression that they’ve really weighed in on the bill—thereby giving the bank lobby bogus ammunition with which to declare victory.

In fact, while bank lobbyists were ecstatic about the interest rate recommendation, not every bank is on board. Bank of America recently announced that it would give small businesses the same protections consumers get under the bill. According to Bloomberg/BusinessWeek, a spokesperson said that the move won’t hurt its ability to extend credit.

Regulators’ Exposure of Accounting Loophole Helped Banks Hide Risk

This story is republished from CFOZone, where you’ll find news, analysis and professional networking tools for finance executives.

Not exactly shocking news but one of the mysteries of the financial crisis is how it came to be that banks ended up with rtransferred to investors.

Sure, it’s well known that the assets banks removed from their balance sheets did not shift much risk to investors after all, thanks to liquidity guarantees they supplied to investors. But that even took former Citigroup vice chairman and Treasury secretary Robert Rubin by surprise, as Rubin said he didn’t know such guarantees existed until after the bank was forced to increase its capital reserves because it had to make good on them.

Now research that came out a year ago but was revised late last month helps clarify what went awry.


It turns out that a conflict between the Financial Accounting Standards Board and federal bank regulators was even more critical than I thought it was when I reported it in 2004. The conflict arose after FASB voted to require commercial banks to consolidate such vehicles after such financing arrangements caused energy trading firm Enron Corp. to fail.

I was aware that the regulators asked the FASB to delay the new accounting rule and that the board eventually provided an exemption for so-called “qualified” special purpose entities, which provided a loophole from consolidation so long as they vehicles weren’t actively managed.

But the full significance of that escaped me until I saw the research, which shows that securitization along the lines of Enron’s — guarantees that limited or even eliminated investor risk — exploded after bank regulators codified the exemption in their capital requirements. Indeed, the exemption essentially paved the way for banks to use more off-balance-sheet financing vehicles that masked their true risk.

How exactly? In late 2004, the Federal Reserve Board, Federal Deposit Insurance Corporation and the Office of Thrift Supervision decided that asset-backed commercial paper put into special purpose vehicles known as conduits would not have to be consolidated for purposes of calculating capital requirements. And the regulators decided that banks need only reserve against 10 percent of the amounts put into conduits even when they guaranteed that investors would be repaid if there were a run on the conduits. Previously, securitizations typically put investors on the hook for that risk.

The research, originally published in May 2009 but revised in late January and entitled “Securitization without Risk Transfer,” found that the amount of subprime assets securitized through such vehicles soared in the wake of the exemption, even though the liquidity guarantees extended to investors meant that little or no risk had been transferred to them.

“Regulation should either treat off-balance-sheet activities with recourse as on-balance sheet for capital requirement and accounting disclosure purposes, or, require that off-balance sheet activities do not have recourse to bank balance sheets,” the authors, Viral V. Acharya and Philipp Schnabl of New York University and Gustavo Suarez of the Federal Reserve, conclude. “The current treatment appears to be a recipe for disaster, from the standpoint of transparency as well as capital adequacy of the financial intermediation sector as a whole.”

Bernanke’s Next Four Years

We’re skipping >75 this week because apparently none of you have any CPA exam questions. That’s sad. Really? None? Well if you do, send them over. Please. JDA needs to eat.

Anyway, let’s talk about Bernanke’s confirmation!

WSJ:

Ben Bernanke won the backing of the Senate for a second four-year term as chairman of the Federal Reserve by a comfortable margin Thursday. Even with that storm behind him, Mr. Bernanke faces formidable political and economic challenges made tougher by the bruising confirmation fight.

Yeah, ok, let’s ignore the fact that the Fed spent the last week buttering up everyone they could to get to push Bernanke through. WSJ made it really easy with a chart of Senators who were going to vote for him, who weren’t, and who were undecided. It was a fucking Fed Telethon trying to save Bernanke’s ass and with a 70-30 vote, apparently they won.


Dallas Fed President Richard Fisher wrote in the WSJ that Congress is Politicizing the Fed but Market Ticker argued that The Fed is Politicizing the Fed. What do you call making a last ditch effort to convince undecided Senators to keep the Bernanke crack flowing? That’s not necessarily the Fed getting political, it’s just them trying to save their own asses.

I’m not going to rant about Zimbabwe Ben and his mission to destroy the dollar. In some ways, I’m glad this thing is over with and Bernanke is the least of all evils (Larry Summers for one) but it’s funny that markets reacted as they did when Bernanke’s confirmation was “up in the air” (LOL, we all knew what would happen).

I would hate to go all conspiratorial and throw out “manipulation” as the culprit, nor can I pretend to know what charts mean.

Don’t miss The Bernanke Confirmation: Incompetence, Indifference and Institutional Inertia via Huffington Post.

DealBook:

The Senate voted 70 to 30 on Thursday afternoon to confirm Ben S. Bernanke as chairman of the Federal Reserve for another four years, Sewell Chan of The New York Times reports from Washington. The confirmation came minutes after senators voted 77 to 23 to end a debate in which critics excoriated the central bank’s handling of the financial crisis.

The confirmation was a victory for President Obama, who had called Mr. Bernanke a critical leader in the nation’s recovery from recession, but the rancor in the debate also signaled the extent to which the Fed, once little known to the public, has become the object of populist anger over high unemployment and bank bailouts.

Grrrrr.

Jr Deputy Accountant and Michael Panzner Discuss 2010 Part II: The Impotent Fed; An Election Year; Waiting for the Recovery

Thumbnail image for Thumbnail image for Thumbnail image for angry bear.jpgIn case you missed part one of JDA’s 2010 Outlook interview with Financial Armageddon’s Michael Panzner, you can find it on Going Concern here.
For the first half of my 2010 talk with Panzner, I focused on the other shoes left to drop; commercial real estate, political backlash, and the threat of the massive bubble still being inflated in China. But even bears have their bright sides and Panzner is no different. So what do we have to look forward to this year? Oh crap, more doom and gloom; sorry, I got my interviews mixed up.


Panzner points to our leaders’ missteps throughout the crisis as a major factor that could place a damper on any hope of recovery. “Many of the problems and imbalances that helped about the crisis have gotten worse,” he says, “That means people have less in reserve than they did before, and many have not positioned themselves for a ‘new normal.’ That suggests the next leg down, economically speaking at least, could be much worse than what we’ve experienced so far.” If only we’d been prepared for the worst instead of coddled into believing everything is better, eh?
When asked to take a guess as to when the Fed would finally raise interest rates, Panzner gave an interesting answer. “In my view, the Fed is no longer in control – of the economy or its destiny. For the most part, market and other forces, not the FOMC, will determine what happens to interest rates in future.” So I guess it doesn’t matter when they’ll raise rates, markets are no longer listening. Or are they?
A big picture sort of guy, Panzner identifies sociopolitical threats as another major concern this year, and with this being an election year (hello, Scott Brown anyone?), I’m willing to go on the record as agreeing wholeheartedly with him (shock). “Wait and see what happens to the social and political mood if and when the economy rolls over,” he says ominously.
Oh, believe me, JDA is waiting. And waiting. And waiting. Still no rollover but dammit, I’ll still be here twiddling my thumbs.
Hopefully I’ll get a chance to check in with Panzner again come summer to see where we are.
Editor’s Note: Want more JDA? You can see all of her posts for GC here, her blog here and stalk her on Twitter.

Regulatory Agencies’ Final Word on FAS 166/167

rules_1668_1668.gifThe Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of Thrift Supervision released their long-awaited final word on new rules for securitized assets, specifically for bank balance sheets:

The federal banking and thrift regulatory agencies today announced the final risk-based capital rule related to the Financial Accounting Standards Board’s adoption of Statements of Financial Accounting Standards Nos. 166 and 167. These new accounting standards make substantive changes to how banking organizations account for many items, including securitized assets, that had been previously excluded from these organizations’ balance sheets.

What does this mean for banks? In simple terms, they’re no longer going to be allowed to hide massive amounts of SPEs and derivative exposure off their balance sheets. Hit the deck!

Banking organizations affected by the new accounting standards generally will be subject to higher risk-based regulatory capital requirements. The rule better aligns risk-based capital requirements with the actual risks of certain exposures. It also provides an optional phase-in for four quarters of the impact on risk-weighted assets and tier 2 capital resulting from a banking organization’s implementation of the new accounting standards.

In case your ass has been under a rock for the last year, FASB came after banks’ asses over the summer. Miraculously, the Fed encouraged this switch, leading me to believe they’re just trying to cover their tracks.
Quadruple Whammy: Regulatory Agencies’ Final Rule on FAS 166/167 [JDA]
See also:
FASB Changes, Toxic Asset Shuffle

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.

The PCAOB Setting a Precedent…for the Fed?

jump to conclusions.jpgFirst of all, before I go anywhere with this, I know GC already gave her a link but this recent Re: the Auditors post on, well, auditors — or rather the lack thereof — is a do-not-miss. It is especially relevant when we’re talking about the usefulness of audits, PCAOB or otherwise.
Anyway.
As many of you already know, the PCAOB is on the chopping block and bad. While we’ll have to let that one work itself out in court, the case against the PCAOB is actually an all-too-familiar argument.


The Federal Reserve System (much like the PCAOB) pulls its regional bank presidents not under direct Presidential directive but because that’s how it has always been. The President appoints a Fed Chairman of course but beyond that, Washington tries to stay as far away from the regional Fed bank structure as possible. Why? That question is a tad too complicated to answer here, so we’ll get into that another day.
The important part here is that the Fed should be closely watching the PCAOB case in the Supreme Court. If the PCAOB is brought before the people of the United States to answer for its alleged recklessness as an agency free from Presidential influence, the Fed may follow soon after.
WebCPA:

The plaintiffs argued that the PCAOB violates the separation of powers principles in the Constitution because the PCAOB’s members are appointed by the SEC and not directly by the president, and they cannot be fired except for cause. Several justices indicated some sympathy for that viewpoint in their questions.

Gee, that sounds just a little too familiar. Seeing as how two-thirds of regional Fed bank directors are chosen by the very banks those regional banks “supervise”, the Fed may have some ‘splaining to do.
So while Bernanke is out there running PR for the Fed System to keep nosy Congressmen out of their business, where is the PCAOB defensive play against SCOTUS? Don’t they have anything to say in their own defense? Apparently not if my experience is any indication.
While most of you know I am not exactly a cheerleader of the PCAOB nor the Fed, I can’t see how consolidating all of our power in Washington can be a benefit either. There is something to be said for the wacky structure of these agencies as it is a Frankenstein of influence instead of a concentrated wave of power emanating from DC.
So watch the PCAOB case closely, Ben Bernanke, it could be you next and you don’t want to have to explain why the banks you regulate pick the soldiers of your precious System.