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About $1.2 trillion in off-balance-sheet assets could end up on the balance sheets of banks that have yet to claim them, or "on no one's balance sheet," a new report claims.
Marie Leone, CFO.com | US
April 23, 2010
New accounting rules governing off-balance-sheet transactions went into effect for most companies in January. As a result, 53 large companies have already estimated that they will have put back an aggregate $515 billion in assets to their balance sheets during the first quarter, according to a new study of S&P 500 companies released by Credit Suisse.
But the future state of the companies' balance sheets remains unclear, since they only consolidated 9% of the $5.7 trillion in off-balance-sheet assets they reported in the fourth quarter of last year. About $4 trillion of the remaining assets will be taken up on the balance sheets of mortgage companies Fannie Mae and Freddie Mac, which guaranteed many of the subprime residential mortgages. The rest of the assets — about $1.2 trillion worth — could find their way to the balance sheets of companies that have yet to claim them, or "on no one's balance sheet," assert report authors David Zion, Amit Varshney, and Christopher Cornett.
Because some assets are lingering in accounting limbo or hidden by murky disclosures, gauging their final effect on company financials could be akin to hitting "a moving target," says the report. Indeed, Credit Suisse notes it's unclear whether all reported estimates issued during the first quarter included deferred taxes, loan loss provisioning, and such off-balance-sheet assets as mortgage-servicing rights. (Selling mortgage-servicing rights is a multibillion-dollar industry.)
The rules that force companies to put such assets back on their balance sheets were issued in 2008 and went into effect at the beginning of this year. They are Topic 860 (formerly FAS 166), which deals with transfers and servicing of financial assets and liabilities, and Topic 810 (formerly FAS 167), the rule governing the consolidation of off-balance-sheet entities in their controlling companies' financial reports.
In reviewing the results and disclosures as of March 11, the study's authors found that only 183 companies in the S&P 500 reported the balance-sheet effects of FAS 166 in their financial results, with 24 providing an estimated impact and 117 reporting either no impact or an immaterial one. Forty-two companies are still evaluating the effects of the new rules, while 317 made no mention of the rules at all. In contrast, 342 companies disclosed the effects of FAS 167, with 29 providing estimates and 214 registering no impact or an immaterial one. That leaves 99 companies still evaluating the FAS 167 impact and 158 making no mention of the financial-statement effects.
Predictably, most of the asset increases belong to companies in the financial sector, where off-balance-sheet transactions such as securitization, factoring, and repurchase agreements are popular. As of Q4 2009, financial-services companies in the S&P 500 had stashed $5.5 trillion and $1.6 trillion, respectively, in variable-interest entities (VIEs) and the now-defunct qualified special-purpose entities (QSPEs). That left a mere $110 billion in assets spread among the QSPEs and VIEs associated with companies in nine other industries.
Assets are returning to balance sheets for several reasons, most notably the Financial Accounting Standards Board's elimination of QSPEs, or "Qs," in 2008, when it became apparent that the structures were being abused. Indeed, Qs were permitted to remain off bank balance sheets if they took a "passive" role in managing the structures' finances. But when the subprime crisis hit, and the mortgages being held in Qs began to fail, banks — with the blessing of regulators — took a more active role, reworking the terms of the entities' mortgage investments. At the time, FASB chairman Robert Herz called Qs "ticking time bombs" that started to "explode" during the credit crunch.
VIEs, on the other hand, are still used. These vehicles are thinly capitalized business structures in which investors can hold controlling interests without having to hold voting majorities. As of the fourth quarter last year, S&P 500 companies parked $1.7 trillion worth of assets in VIEs.
The revised standards were supposed to wreak havoc on bank balance sheets because, among other things, the rules for keeping loan-related assets off the books would be rewritten. At the time, bankers expected the rewrite would force them to consolidate big swaths of assets that were being held in VIEs and Qs. And consolidating the assets from the entities would have required them to increase the amount of regulatory capital they kept on hand — a charge to cash — and thereby reduce the amount of lending they could do. Dampening lending during a credit crisis, argued bankers, would hurt the recovery.
Since their enactment, the accounting rules have affected their industry big time. Of the companies reporting an impact, nine purely financial-sector outfits plus General Electric account for 96% of the $515 billion being consolidated during the first quarter, says Credit Suisse. Of that group, which includes Bank of America, JP Morgan Chase, and Capital One, Citigroup tops the list with an estimated $129 billion in assets being brought back on the books in the first quarter — which represents 7% of its existing total assets. The newly consolidated assets come in all shapes and sizes, says the report: $86.3 billion in credit-card loans, $28.3 billion in asset-backed commercial paper, $13.6 billion in student loans, and $4.4 billion in consumer mortgages, for example ($5 trillion of the $5.7 trillion held in VIEs and Qs is mortgage related). Citigroup also disclosed a $13.4 billion charge for setting up additional loan loss reserves and eliminating interest lost from consolidating the assets.
Of the companies that disclosed the financial-statement impact, only eight estimated the increase to be more than 5% of total assets, says Credit Suisse. Invesco was the hardest hit, reporting the highest percentage at 55%, bringing back $6 billion worth of assets during the first quarter. Invesco's assets are parked in collateralized loan obligations and collateralized debt obligations.
Nonfinancial companies, such as Harley-Davidson and Marriott International, also reported relatively big percentage jumps compared with existing assets. Harley's additional assets represent 18% of existing assets, or $1.6 billion; Marriott's consolidation represents 13% of its assets, or $1 billion.