The Accounting Consensus: Implications for Accounting Education, Research and the Profession Shyam Sunder Yale School of Management Accounting Standards Board of Japan Tokyo, January 20, 2011

Specifics vs. Structure Most debate on IFRS and accounting standards is confined to merits of specific standards This narrow definition of debate does not address many important issues We need to go beyond the confines of specific details of standards to how we think of the role and scope of standards, and the structure of institutions we create to set standards

Financial Reporting: Some Commonly-held Beliefs

(c) 2005 Sunder, Nanny Knows Best 1. Universal Standards Universal standards of financial reporting applied across time, economies, industries and corporate size and organizational forms best serve the constituent interests Standardization does save costs and effort, (electrical plugs, clothing, cars, street grids, commercial codes) Becomes counterproductive beyond certain limits How do we know where to stop? Rhetoric of universal accounting standards and universal language 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

(c) 2005 Sunder, Nanny Knows Best 2. The Static Ideal There exists a set of financial reporting standards that, once discovered and implemented, will induce corporations and their auditors to prepare the best attainable financial reports Dynamics of the game between managers and standard setters makes any such static ideal all but impossible Standards is only a (small) part of the problem 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

(c) 2005 Sunder, Nanny Knows Best 3. People or Structure If we select knowledgeable, experienced, self-less, public-spirited, and wise individuals to constitute bodies that devise accounting standards through deliberation and due process, we can improve financial reporting Individuals stand where they sit Much emphasis on the quality of individuals, too little attention to the structure of game they are asked to play 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

4. Engineering Standards through Deliberation It is possible to construct or discover better financial reporting standards through deliberation in properly organized corporate entities (such as the IASB, the FASB, etc.). Assumes that such bodies can know the consequences of their actions History does not support the proposition 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

5. Specialization in Setting Standards Specialist standard setting bodies, standing ready to address new problems, inquiries and requests for clarifications help improve financial reporting Their existence encourages a new “clarification” game targeted at them They must keep a full agenda (performance) Revenue and budget pressures Over time, their output must accumulate to a thick rule book 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

(c) 2005 Sunder, Nanny Knows Best 6. What is Good and Bad? Standard setters can tell which standards are better and why. Little evidence that they know, or can know Cost-of-capital is the result of complex interactions among many factors (including accounting) These influences cannot be sorted out by ex ante analysis Ex post analysis of data to assess the impact on cost of capital may be possible 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

(c) 2005 Sunder, Nanny Knows Best 7. Standards Monopolies Granting monopoly power in a given jurisdiction to standards written by a given body can help improve corporate financial reporting Informational disadvantage of a monopoly No opportunity for experimentation No opportunity to learn from the experience of alternatives No pressure to do better, or to correct errors 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

8. Competition and Race to the Bottom A regime that encourages reporting entities to choose among the standards written by competing organizations (and paying them a royalty for the privilege) induces a “race to the bottom” to devise less demanding standards Counter examples (Stock exchanges, bond rating services, appliance standards, college accreditation, bank regulation, corporate charters across U.S. states, etc.) 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

9. Force and Effectiveness Increase in the power of enforcement behind authoritative standards improves compliance and quality of financial reporting Increased enforcement also increases resources devoted to evasion Draconian punishments do not necessarily induce better behavior Crime, alcohol and drug abuse 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

10. Statutory Approach Dominates Common Law The quasi-statutory approach to setting accounting standards dominates a common law approach to financial reporting Evidence? Constitution (U.K., U.S., Europe) 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

11. Written Standards Dominate Social Norms Written standards backed by power of enforcement work better than unwritten social norms backed only by internal and external informal sanctions Social norms govern great parts of our lives including many aspects of law Insider trading Guilty beyond reasonable doubt Private commercial codes (cotton, diamond trades) 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

12. Who defends the middle ground? The ideal accounting regime would consist of all written standards or all social norms Easier to make the extreme cases for standards or norms alone Difficulty of defending the middle ground where both may co-exist, as they do in many other aspects of life 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

13. New Problems, New Solutions Financial reporting and governance problems originated in the 20th century History tells us otherwise Governance problems of the East India Company Clive, Hastings, and the Company’s Court of Directors 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

14. Financial Reporting is Getting Better Seventy years of standardization of financial reports (in U.S.) has helped improve the quality of financial reporting Evidence? Is a thicker rulebook indication of better financial reporting? Perfect correlation between accounting and stock returns? How do we judge if our financial reports are getting better? 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

15. Fewer Alternatives, Better Reports Fewer the alternative treatments the reporting entities are allowed to choose from, the better the quality of financial reporting Fewer alternatives also tie the hands of the management of well-run companies who may wish to signal their confidence, competence and prospects by choosing reporting practices others find difficult to emulate 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

16. Auditor’s Bargaining Power Well-specified standards enhance the bargaining power of the auditor vis-à-vis the client Standards also encourage clients to demand: show me the rule Reduced reliance on judgment More detailed the standards, greater the part of accountant’s work that can be replaced by a computer, and lower the value of the service 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

17. Accounting & Auditing Games Written standards constrain the tendency of managers, auditors and investment bankers to play accounting and auditing games On the contrary, they encourage and facilitate game-playing by reducing uncertainty about what is, and is not, acceptable 3 percent SPEs => Enron 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

18. Individual responsibility Written financial reporting standards strengthen the individual responsibility of managers, auditors, and investment bankers for fair representation On the contrary, they undermine individual responsibility for fair representation and the big picture by shifting attention to meeting the letter, not spirit, of the specific provisions and their wording 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

(c) 2005 Sunder, Nanny Knows Best 19. Education Written standards make it easier to educate better accountants and attract talent to the profession Written standards degrade the class room from reasoning and intellectual debate to rote memorization, reinforce street image of accounting as boring and mechanical They make it less attractive to young talent 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

20. Nothing’s New under the Sun Have I said something new? I wish. William T. Baxter (Professor Emeritus, LSE), made many of these arguments over half-a-century ago (“Recommendations on Accounting Theory” in Baxter and Davidson, Studies in Accounting Theory, 1st edition). 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

Beware of Consensus A different perspective You would be left behind if you do not follow the crowd Washington Consensus Accounting Consensus—five main elements

Accounting Consensus 1 The standards developed should be confined to principles, and not become detailed rules Nobody can tell which is which IFRS vs. FAS, yet plans to adopt FAS wholesale Fair values: principle or rhetorical device

Accounting Consensus 2 A single set of high quality written standards of financial reporting applied to all companies (at least the publicly traded ones) in the world will improve financial reporting by making financial reports more comparable, and thus assist investors and other users of financial statements make better decisions All prefer high quality, but what is it (Joyce et al. Principles-comparability contradiction Accounting for research & development costs (FAS 2) Evidence that accounting standards help investors or managers make better decisions?

Accounting Consensus 3 The best way to develop such standards is to create a single deliberative corporate body consisting of appropriate experts with a proper governance structure and legally assured funding, functioning under the oversight of statutory regulatory authorities such as the SEC and the EC Difficulty of assessing proposed standards Even simple engineering design need field trials Complexity of social institutions, risk of getting boxed into a wrong standards Division of simplicity and complexity between strategy and institutions Ecosystem view of financial reporting system Competition with no tax revenues

Accounting Consensus 4 To this end, the operations of the FASB and the IASB should be gradually merged into one corporate body and one set of standards to be called IFRS From social norms to uniform written standards Effect of uniformity of education, research and profession Compare accounting education to education for other professions

Accounting Consensus 5 This single set of standards should be practiced in the U.S., EC, and elsewhere, and the U.S. educational system should prepare itself to integrate IFRS into its curricula so U.S. graduates will be able to prepare, use, and audit financial reports based on IFRS Educational consequences an afterthought at best Effect of expansion of written standards on classroom discourse Educational capacity: chance to shift to general principles of accounting Place of accounting in the university: medicine or plumbing

The Problem of Setting Efficient Standards Criteria Generation of alternatives Evaluation of alternatives Complex interactions among accounting, capital and labor markets Facilitation of evolution of accounting norms Balancing statutory and common law Balancing adjustment speed and errors No substitute for personal responsibility The nanny does not know, but can help 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

(c) 2005 Sunder, Nanny Knows Best How Can the Nanny Help? Government, quasi-government or private sector bodies can play a positive role in evolution of norms of accounting through oversight No monopoly jurisdiction Competition with alternatives (royalties) Opportunity to experiment Co-existence of multiple sets of standards for different clienteles—diversity essential to evolution Excel conversion workbooks (high R-square) Personal responsibility for fair representation Accounting Court: guilty beyond reasonable doubt 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

In Contrast to IASB (FASB) Command & Control View To develop accounting standards: A single set (monopoly?) Of high quality (what does that mean?) Understandable (to who?) Enforceable (stick, not norms) Global (no clientele or diversity) Are we ready for an alternative mind set about financial reporting? 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

Whither Accounting: Windows™ or Open Systems Comfort vs. choice Uniformity and stagnation vs. dynamic change Predictability vs. some disorder High prices or the advantages of technological progress Financial reporting as an eco-system or a machine (garden or a building) Huxley or Hayek Nanny or personal responsibility Role of accounting researchers/professors? 11/8/2018 (c) 2005 Sunder, Nanny Knows Best

Concluding Remarks In the preface to his Dictionary, Johnson wrote about his “fortuitous and unguided excursions into… the boundless chaos of a living speech." Can authoritative uniform standards without collaboration with social norms bring a semblance of order to the chaos to financial reporting? After seven decades of incessant efforts, the answer stares us in the face

Shyam.sunder@yale.edu www.som.yale.edu\faculty\sunder Thank You. Shyam.sunder@yale.edu www.som.yale.edu\faculty\sunder