Tag Archives: regulation

Ethics – Fundamental Attribution Error

When we read the stories about Enron, HealthSouth, and other accounting scandals, what is usually mentioned is the malicious intent of the executives to perpetrate a fraud. This is because “bad people do bad things,” right? Although the stories are instructive of how things can go wrong in an organization and how it can affect those involved, it is easy to forget about how we are all susceptible to the same temptations.

The fundamental attribution error is the human tendency to attribute the cause of these wrongdoings to the character of the individual who committed them. It’s called an error because, overwhelmingly, human behavior is determined more by environment than inherent personality traits. This error of perception works both ways, too: when something goes right, we tend to think that it was due to our virtues and/or skills rather than external factors (sheer luck, a good supporting staff who helped along the way, or a stock-market generally on an uptick). This, combined with the fact that people tend to rate their ethical inclinations higher than they actually are, is a troublesome sign for working professionals in just about every field. A fraud can begin with an innocent mistake, and continue because the perpetrator needs to cover it up. Of course, this is because they do not believe themselves to be a bad person.

However, being aware of the problem is an important step toward preventing future unethical behavior. That accountants spend a great deal of time thinking about internal control perhaps serves as a tribute to this way of thinking. We restrict access and separate duties of employees in a manner that reflects the notion that environmental factors are strong determinants of behavior. Surely these companies do not go around hiring bad people all the time so that they feel the need to exercise constant vigilance. These employees go along with it without feeling as though they are distrusted because the company thinks they are bad people and thus likely to steal from them. It is an unfortunate fact of life, but you can put an otherwise good person in a position where they can commit fraud without oversight or control, and you will run the risk of a fraud occurring.Thumbnail_FundamentalAttributionError_01_21_14_Version_01-1024x576

For more about the psychological aspects of ethics, see Ethical Decision Making: More Needed Than Good Intentions and the Ethics Unwrapped Series, both by Robert Prentice, McCombs School of Business.

Macroprudential Regulation: Moving Beyond Dodd-Frank & Basel III

Last semester I had the pleasure of taking Law for Finance with the renowned Professor Prentice. It was incredibly helpful to learn how our work as accountants flows through a regulatory framework that seeks to create a level playing field for companies issuing securities and their investors. As auditors we’re most familiar with Sarbanes-Oxley and GAAP/GAAS, but these are only a few pieces of the puzzle that contribute to the rational accumulation and allocation of capital so critical to economic growth.

It’s also important to look at what policymakers call “macroprudential regulation”. These are regulations which seek to mitigate the damage done by the emotional swings among financial intermediaries from exuberant optimism to irascible pessimism, also known as systemic risk or the boom-bust cycle. The Dodd-Frank Act was an important new addition to the macroprudential regulatory framework by requiring the trading of derivatives to be on exchanges and prohibiting banks from gambling with depositors’ money in financial markets. Accountants are instrumental in implementing these regulations and monitoring for continued compliance. Likewise, through the calculation of the Allowance for Loan and Lease Losses (ALLL), accountants must be familiar with the credit risk models mandated by Basel II, an international accord between central banks designed to minimize systemic risk.

During my Big 4 internship I examined credit risk models for a large retail bank to verify that their ALLL was properly calculated. This ALLL feeds into the next pillar of Basel II, capital adequacy standards that help the banking system through downturns and protect deposit insurers like the FDIC.  In light of the 2008 financial crisis, regulators made the capital adequacy guidelines more stringent with the introduction of Basel III. However, few are optimistic that this will prevent future economic bubbles.

Academics have argued that this patchwork of regulations around depository institutions is a case of the doctors treating symptoms instead of the underlying disease. In accounting terms, the disease is that depositors do not have an investing cash outflow when they deposit their money, whereas depository institutions have a financing cash inflow. No other transaction in the economy has this accounting asymmetry, which is commonly known as fractional reserve banking. Professor Jesús Huerta de Soto, from Rey Juan Carlos University in Spain, wrote a book in 2005 (PDF) detailing how this shaky accounting creates systemic risk in the banking system. Most recently, Michael Kumhof, a professor at Stanford University and one of the top economists at the IMF, published a paper (PDF) detailing how a financial system could simultaneously transition from fractional reserve banking to 100% reserves, reduce excessive leverage, and prevent the boom-bust cycle.

I had the honor of meeting Professor Kumhof at the Association for the Study of Peak Oil & Gas’ annual conference which was co-hosted by the University of Texas. He was optimistic that policymakers will come around to what is called the “Chicago Plan”, originally devised by a group of economists at the University of Chicago.

In a nut shell, the plan would have depository institutions finance their investing activities from private investors and loans from the government rather than lending out deposits. Deposits would be much like segregated accounts in a trading house or bailments; the bank is a custodian of the funds but is not allowed to lend them out. This would prevent excessive credit creation since banks would have to borrow real savings, much like a mutual fund or a securitization deal that issues bonds.

Perhaps the most fascinating aspect of the plan is that depository institutions in the United States would have to borrow 180% of GDP from the government to meet the 100% reserve requirement. This would mean that the Federal Government would have a negative level of net debt. Similarly, this would immediately solve the European sovereign debt crisis.

To prevent deflation, the government would have to create and spend new money at a rate of 2 or 3% per year, which would help reduce the budget deficit. This nominal money growth would be one aspect of macroprudential policy under the Chicago Plan. The amount and riskiness of credit creation would still be controlled by capital adequacy rules like Basel III and interest rates would be set by how much the government (or an independent central bank) charges financial institutions for additional liquidity needed to finance large productive investments.

Professor Kumhof estimates that changing the regulation of deposits would result in a 10% boost to GDP growth. This is why he is most optimistic that the Chicago Plan will, over the coming years, become a cornerstone of financial reform. Here is his presentation of the paper he published in August:

Accountants will play an important role in advising depository institutions with restructuring their balance sheet and revising their internal controls to reflect the new accounting treatment of deposits. That said, the greatest benefit for us will be that the manic instability of financial markets will be give way to steady real economic growth.

What benefits or drawbacks do you see from the Chicago Plan?

CPA Exam Update + More

As the semester is quickly coming to a close, I thought I would give another CPA exam update and describe the end of the semester.

So I took my first section of the CPA exam, and I won’t sugar coat it – it went pretty badly.  It was my first section and it definitely helped me learn what I did well and what I didn’t do well.  I definitely need to change my study method for the next one.  Doing more practice questions is key, as I concentrated more on learning the material than practicing questions.  I also need to realize that the tests are pretty hard and requires probably more studying than I put into it.  For the next section, I plan on doing more practice questions throughout my studying to make sure I am on track and that I don’t feel as unprepared on the day of the test as I did for this one. Continue reading CPA Exam Update + More

Thankful for Home

Thanksgiving brought a busy half week of engaging with family and avoiding anything explicitly school related. I returned to Austin late Saturday night, woke up Sunday and went to Starbucks to begin my last tax research memo!! As I turned on my computer and logged onto the Starbucks page, I found a fascinating video entitled Ripe for Change.

Since I am an expert procrastinator, the topic of anything but tax research caught my eye. Since I am from California, this topic of food production hits close to home. And as we just finished celebrating Thanksgiving, food seemed to be an appropriate topic. Watching the video, I found that the issues it addresses within the food industry are highly relevant to us as accountants.

One such issue is regulation. The tensions between the need for regulation and its burden have been prevalent recently, and are particularly relevant in the financial industry that many of us will enter from the MPA program.

In the documentary as multiple farmers comment on the same trend, for example mechanical picking, we see that there is not always a clear cut way to respond to the availability of new technology or situations; we even see that sometimes the alleged problem is not as obvious as it seems. Continue reading Thankful for Home