U.S. Accounting for the Fiscal Response to the Financial Crisis

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1 U.S. Accounting for the Fiscal Response to the Financial Crisis

2 2

3 Principal Entities Involved in Fiscal Response Department of the Treasury FASAB standards (The Federal Accounting Standards Advisory Board) September 30 year-end Federal Deposit Insurance Corporation FASB standards December 31 year-end Federal Reserve not part of the federal reporting entity 3

4 Application of GAAP Many of the transactions have occurred after September 30 and have not yet been reported on a GAAP basis FASAB statements do not directly address some of these transactions because they are new to the federal government. In such cases, agencies follow the GAAP hierarchy to determine the appropriate accounting principles to be applied. The Federal Accounting Standards Advisory Board (FASAB) is developing a new accounting standard that generally will adopt the GAAP hierarchy currently contained in auditing standards. 4

5 FASAB Credit Reform Accounting - Loans and Loan Guarantees loans receivable - present value of expected net cash inflows from the loans. liability for loan guarantees - present value of estimated net cash outflows due to the loan guarantees. adjusted for modifications made during the year to loans and guarantees outstanding and for reestimates made as of the end of the year to the subsidy allowances or loan guarantee liability for loans and guarantees outstanding. discount rate interest rate of marketable Treasury securities with similar maturity to the cash flows, applicable to the period during which the loans are disbursed/ guaranteed for budget purposes, Troubled Asset Relief Program (TARP) transactions are to follow modified credit reform, where the discount rate is adjusted for market risks. 5

6 FASAB - Contingent Liabilities Contingent liabilities - recognized when all of these three conditions are met: A past event or exchange transaction has occurred A future outflow or other sacrifice of resources is probable (more likely than not) The future outflow or sacrifice of resources is measurable If a range and some amount within the range is a better estimate than any other amount within the range, that amount is recognized. If no amount within the range is a better estimate than any other amount, the minimum amount in the range is recognized and the range and a description of the nature of the contingency should be disclosed. 6

7 FASAB - Contingent Liabilities Contingent liability disclosed if any of the conditions for liability recognition are not met and there is at least a reasonable possibility that a loss or an additional loss may have been incurred. Disclosure in this context refers to reporting information in notes regarded as an integral part of the basic financial statements. Disclosure should include: the nature of the contingency an estimate of the possible liability, an estimate of the range of the possible liability, or a statement that such an estimate cannot be made. 7

8 Capital Purchases (Preferred Stock and Warrants) Fannie Mae and Freddie Valued at cost, with allowance for impairment Stock and warrants received in exchange for guarantee (cost = fair value at acquisition) Warrants Black-Scholes Option Model Preferred stock - interpolation of market prices for (i) Fannie Mae and Freddie Mac subordinated debt, as adjusted for the tax advantage of stock dividends compared with taxable interest, and (ii) Fannie Mae and Freddie Mac preferred stock. 8

9 Capital Purchases (Preferred Stock and Warrants) Treasury Troubled Asset Relief Program (TARP) Budget Initially recorded 100% of payments as budget expenditures Changing to modified credit reform accounting (discount rate is adjusted for market risks) Possible GAAP basis Modified credit reform Fair value Cost, with an allowance for permanent impairment 9

10 Deposit Insurance and Debt Guarantees FDIC Deposit Insurance limits of coverage were recently raised from $100,000 to $250,000 per depositor through December 31, 2009 Revenue is recorded based on quarterly assessments from insured depository institutions. Such assessments may be raised to allow FDIC to maintain reserve ratios with statutory ranges. Currently, FDIC has levied a special assessment on insured depository institutions to raise reserve ratios. 10

11 Deposit Insurance and Debt Guarantees FDIC records a contingent liability and a loss provision for FDIC-insured institutions that are likely to fail within one year of the reporting date, absent some favorable event such as obtaining additional capital or merging, when the liability becomes probable and reasonably estimable. 11

12 Deposit Insurance and Debt Guarantees FDIC established new Temporary Liquidity Guarantee Program (TLGP) Debt guarantees eligible newly issued senior unsecured debt Full deposit insurance coverage for non-interest bearing deposit transaction accounts Separate fee charged FDIC will make additional assessments on FDICinsured depository institutions to recover any excess of costs of the TGLP over fees received. FASB guarantee accounting 12

13 Deposit Insurance and Debt Guarantees Other guarantees - accounting basis under review Citigroup Treasury and FDIC to share losses with Citigroup on an asset pool for any losses in excess of $39.5 billion. Treasury and FDIC have a maximum exposure to any losses that may be offset by the value of the preferred stock issued to them by Citigroup. Bank of America Treasury and FDIC to share losses with Bank of America on an asset pool for losses in excess of $10 billion. Treasury and FDIC have a maximum exposure to any losses that may be offset by the value of the preferred stock and the warrants issued to them by Bank of America 13

14 Mortgage Backed Securities (MBS) Under the authority of the Housing and Economic Recovery Act of 2008 (HERA), Treasury is making MBS purchases (issued by GSE s) in the open market. As of September 30, 20008, Treasury planned to hold its portfolio of MBS to maturity unless, based on mortgage market conditions, sales are necessary. The MBS program is accounted for under traditional credit reform accounting. For fiscal year 2008, GSE MBS subsidy rate was negative, indicating Treasury expects to earn a return on its investments in these securities, and resulting in recognition of a gain on such securities. 14

15 Status of Fannie Mae and Freddie Mac Under HERA, on September 2008, the U.S. government placed Fannie Mae and Freddie Mac under conservatorship. The Office of Management and Budget (OMB) determined that, at that time, the GSE s would not be included in the budget. Statement of Federal Financial Accounting Concepts (SFFAC) No. 2 provides conclusive and indicative criteria to be used in determining whether an entity should be consolidated in the federal government s GAAP financial statements. 15

16 Status of Fannie Mae and Freddie Mac Fannie Mae and Freddie Mac were not consolidated in the federal government s financial statements. it is not included in the budget (the conclusive criteria), the control was deemed temporary consistent with treatment of conservatorships and receiverships at FDIC. this position will be reevaluated, based on any change in conditions. 16

17 Questions? 17

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