Volume 24, Issue 2 pp. 307-342
Article
Open Access

A Survey of Research on Fair Value Accounting for Financial Institutions*

Darren Henderson

Corresponding Author

Darren Henderson

Wilfrid Laurier University

Corresponding author.

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Kaleab Mamo

Kaleab Mamo

Wilfrid Laurier University

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First published: 31 March 2025
*

Accepted by Justin Jin. We thank Stephen Sapp for helpful comments. We are grateful to Andrea Down for research assistance. Both authors appreciate the financial support of Manulife Financial. Darren Henderson thanks the William Birchall Foundation Fellowship in Accounting for research funding.

Abstract

en

Even though fair value accounting (FVA) enjoys widespread support from standard setters around the world, the practice of marking assets and liabilities to market remains controversial. While FVA affects all firms to a certain extent, financial institutions are most affected due to the nature of the assets that they hold. In this paper, we first discuss fair value measurement and its application before exploring the consequences of FVA, including its impact on regulatory capital. We then discuss key benefits and challenges of FVA. Standard setters believe that FVA provides the most relevant information to financial statement users; however, the increased relevance comes with a cost of reduced reliability due to the estimation involved. More recently, concerns have been raised about FVA leading to procyclicality and contagion that can cause or exacerbate boom and bust cycles. After summarizing the literature, we identify opportunities for additional research.

Résumé

fr

Enquête sur la recherche portant sur la comptabilité à la juste valeur pour les institutions financières

Quoique la comptabilité à la juste valeur (CJV) jouisse d'un vaste soutien de la part des organismes de normalisation du monde entier, la pratique consistant à évaluer les actifs et les passifs au prix du marché demeure controversée. Bien que la CJV ait une certaine incidence sur toutes les sociétés, les institutions financières sont les plus touchées en raison de la nature des actifs qu'elles détiennent. Dans cette étude, nous abordons d'abord l'évaluation de la juste valeur et son application, puis nous nous penchons sur les conséquences de la CJV, dont son impact sur le capital réglementaire. Nous discutons ensuite des principaux avantages et défis associés à la CJV. Les organismes de réglementation sont d'avis que la CJV fournit les renseignements les plus pertinents aux utilisateurs des états financiers; toutefois, cette plus grande pertinence s'accompagne d'un coût, soit une réduction de la fiabilité en raison des estimations qu'elle suppose. Plus récemment, on a formulé certaines préoccupations selon lesquelles la CJV mène à la procyclicité et à la contagion, ce qui peut causer ou exacerber des cycles d'expansion et de ralentissement. Après avoir offert un sommaire de la littérature à ce sujet, nous cernons des possibilités de recherche additionnelle.

1 INTRODUCTION

Fair value accounting (FVA) gained momentum in the 1980s after the savings and loan (S&L) crisis was partly attributed to the delayed recognition of losses required by accounting rules at that time (European Central Bank [ECB], 2004). Under FVA, assets and liabilities are recorded at fair value (FV), which is the current traded market value or an estimate thereof. The S&L crisis was believed to be worsened due to the shortcomings of the historical cost accounting (HCA) system in use at that time. S&L institutions invested primarily in long-term fixed rate mortgages funded by short-term deposits, which exposed the institutions to significant interest rate risk. When market interest rates rapidly increased, S&L's funding rates surpassed the expected rate of return from their assets, which resulted in significant losses because short-term rates paid on deposits increased above the expected return from mortgage assets. Under HCA, many institutions appeared solvent based on historical cost (HC) measurement of their assets, while the assets' FVs had declined substantially due to rapid increases in market interest rates. FVA would have shown large deficits for these firms. HCA failed to recognize the embedded losses in a timely manner, delaying potential corrective action by external stakeholders.

FVA would have recognized the entirety of expected losses immediately, leading to more timely recognition of the problem and thus swifter action (ECB, 2004). Additional impetus towards the implementation of FVA stemmed from Japanese banks' failure to identify non-performing loans in a timely manner. In the aftermath of the Japanese housing bubble of the late 1980s, banks were slow to write down nonperforming loans due to restrictive definitions. FVA would have required the decreasing value of assets to be more rapidly reflected on their balance sheets and thus allowed a more transparent view of the full extent of market-wide changes, potentially leading to quicker reactions that would have lessened the impact of the crisis (ECB, 2004).

In the aftermath of the S&L crisis, the FASB introduced Statement of Financial Accounting Standards (SFAS) 115, Accounting for Certain Investments in Debt and Equity Securities (FASB, 1993). This standard serves the FASB's mandate of establishing rules that provide decision-useful information. SFAS 115 requires many investments to be reported at FV. Due to primarily holding such investments, the reporting of financial institutions is significantly affected. The FASB followed up with subsequent standards that relied heavily on FV: SFAS 133, Accounting for Derivative Instruments and Hedging Activities (FASB, 1998); SFAS 123R, Share-based Payments (FASB, 2004); and SFAS 159, The Fair Value Option for Financial Assets and Financial Liabilities (FASB, 2007). The FASB provided its formal definition of FV and clear FV measurement principles in SFAS 157, Fair Value Measurements (FASB, 2006).

The IASB followed a similar path by issuing International Accounting Standard (IAS) 32, Financial Instruments: Disclosure and Presentation (IASB, 1995); IAS 39, Financial Instruments: Recognition and Measurement (IASB, 1998); and IFRS 2, Accounting for Share-based Payments (IASB, 2004b). In 2003, the IASB amended IAS 39 to include its first formal definition of FV, and in 2005, to include a FV option similar to SFAS 159. The IASB updated its definition of FV and provided clear FV measurement principles (analogous to SFAS 157) in IFRS 13, Fair Value Measurement (IASB, 2011). The IASB then issued IFRS 9, Financial Instruments (IASB, 2014) to replace IAS 39 starting in 2018. IFRS 9 provided a simplified FV classification model that diverged from FASB standards.

While the IASB and FASB similarly require FVA for most financial assets and financial liabilities, the IASB goes further by requiring FV for nonfinancial assets such as biological assets under IAS 41, Agriculture (IASB, 2000) and allowing FV for investment properties under IAS 40, Investment Property (IASB, 2003c); for property, plant and equipment (PP&E) under IAS 16, Property, Plant and Equipment (IASB, 2003a); and for intangible assets under IAS 38, Intangible Assets (IASB, 2004a). By allowing or requiring the use of FVA for a wider range of assets, the IASB is demonstrating its belief that the increased relevance associated with current values outweighs the potential for decreased reliability.

The FASB articulates its logic for supporting FV in SFAS 159: “The Board considers fair value measurements of financial instruments to be more relevant to financial statement users than cost-based measurements because fair value reflects the current cash equivalent of the entity's financial instruments rather than the price of a past transaction” (para. A3(d)). HCs are believed to become less relevant as they move further away from the transaction date. Conversely, FVs provide the most current information to support decision-making (e.g., Barth, 1994; Barth et al., 1996). Nevertheless, FVs are generally recognized to be less reliable due to the judgment involved with estimation and potential divergence from fundamental values (e.g., Eccher et al., 1996; Nelson, 1996). Furthermore, FVA can lead to procyclical effects as FV decreases necessitate asset sales, which can cause further decreases in FV, which in turn lead to additional asset sales (e.g., Bhat et al., 2011; Merrill et al., 2012). In fact, FVA was considered one of the major culprits for the severity of the global financial crisis (GFC) of 2007–2009. Many blamed FVA for exacerbating the crisis by compounding the boom-bust cycle through procyclical bank leverage (e.g., Adrian & Shin, 2010; Novoa et al., 2009; Plantin et al., 2008) and through contagion effects stemming from asset prices deviating from fundamental value (e.g., Cifuentes et al., 2005; Laux & Leuz, 2009).

In a recent turnabout that echoes earlier arguments relating to the S&L crisis, HCA is partly blamed for the 2023 failures of Silicon Valley Bank (SVB), First Republic Bank, and Signature Bank (e.g., Beatty et al., 2023; Granja, 2023). As a specific example, SVB held a large portion of its assets in long-term US treasuries that used HCA for measurement as held-to-maturity securities. As a result, SVB did not recognize unrealized losses on these securities when interest rates rose rapidly in 2022 and 2023. The bank failed and was put into Federal Deposit Insurance Corporation (FDIC) receivership following a run by its uninsured depositors. SVB would have recognized large losses if it was forced to mark its investments to market, which could have forced better risk management by the bank and earlier regulatory intervention.

While FVA is believed to provide more relevant information for supporting decision-making, not everyone believes that decision usefulness should be the sole objective of financial reporting. Some advocate the stewardship or accountability view of financial reporting, which focuses on managements' accountability to stakeholders as the primary objective (Ijiri, 1983; Pro-Active Accounting Activities in Europe, 2007). The prior IASB Conceptual Framework similarly presents stewardship as a primary objective (IASB, 2008). Accountability demands objective and verifiable information that demonstrates management's effort and progress in faithfully executing the company's business plan to generate value for shareholders. Nissim and Penman (2008) argue that HCA achieves this goal by recognizing value added only when it is confirmed by actual transactions, whereas FVA recognizes the present value of potential outcomes. Overall, FVA is more consistent with the modern notion of accounting put forward by the FASB, which states that financial reporting must be decision-useful. The stewardship view tends to favor HCA.

This paper proceeds as follows. In Section 2, we discuss the definition of FV and how FVs are measured in practice. In Section 3, we discuss how extensively FVA is applied, and in Section 4, we discuss the consequences of FVA. In Section 5, we discuss the primary benefits of FVA. Section 6 discusses key challenges associated with FV. We identify areas warranting further study in Section 7, and Section 8 concludes our paper.

2 WHAT IS FAIR VALUE?

The application of some form of FVA dates to the 1970s or earlier (McDonough et al., 2020); however, standard setters did not provide a formal definition of FV until fairly recently. For example, SFAS 115 (FASB, 1993) provided no formal definition of FV. Rather, it stated that quoted market prices, when available, provided the most reliable FV measurement and that it was possible to make reasonable estimates when quoted market prices were not available. Similarly, the initial version of IAS 39 (IASB, 1998) provided no formal definition of FV.

Standard setters finally provided a formal definition in the 2000s when the FASB and IASB defined FV using a theoretical exit value concept. The IASB included the first explicit definition of FV in its revision of IAS 39 (IASB, 2003b): “Fair value is the amount for which an asset could be exchanged, or a liability settled, between knowledgeable, willing parties in an arm's length transaction” (para. 9). Soon after, the FASB provided its definition of FV in SFAS 157 (FASB, 2006): “Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date” (para. 5). The IASB adopted this definition of FV in IFRS 13 (IASB, 2011, para. 9).

SFAS 157 (FASB, 2006) and IFRS 13 (IASB, 2011) also provide FV measurement hierarchies. FVs are ideally measured using quoted prices in active markets (Level 1 inputs), which bases FVs on actual transactions. In the absence of quoted prices, FVs should be estimated using observable inputs, such as market prices for similar assets and liabilities (Level 2 inputs), or using unobservable inputs that necessitate the use of a valuation model (Level 3 inputs). Level 3 FVs are often referred to as “mark-to-model.” The amount of management judgment increases across the FV levels: Level 1 requires little or no judgment, while Level 3 requires a significant amount of judgment. Such judgment has led to Level 3 FVs often being described as “marking-to-myth” (Acharya & Ryan, 2016; Kolev, 2009).

Level 1 and Level 2 inputs rely on the assumption of orderly market transactions at the measurement date. Determining if the relevant markets are orderly proved to be difficult during the GFC of 2007–2009. Following significant market dislocation at this time, standard setters issued FASB Staff Position (FSP) Financial Accounting Standard (FAS) 157-4 (FASB, 2009) to clarify the meaning of “orderly transactions” and concluded that market conditions during the GFC did not constitute orderly transactions. They allowed firms to make significant adjustments to market prices when markets were sufficiently illiquid, which could include the use of Level 3 inputs.

Under the current exit value−based definition, FV is a non-entity-specific concept that excludes any value added by the specific holder of the asset or liability. While the use of exit value has become more common, other candidates exist for FV measurement, such as value-in-use or replacement cost (i.e., entrance value). Landsman (2007) points out that exit value may be difficult to determine, particularly for assets that are specific to a given entity. Furthermore, Benston (2008) discusses the difficulty in determining exit value in practice; he notes that even in the FASB's own illustrative examples, value-in-use or replacement cost are occasionally used instead of exit values. In summary, even the definition of FV remains controversial and difficult to apply in practice.

3 HOW EXTENSIVELY IS FVA APPLIED?

While much of the theoretical academic work presumes an environment where FVA applies to all assets and liabilities (e.g., Allen & Carletti, 2008; Cifuentes et al., 2005; Corona et al., 2019), the actual scope of FVA in practice is more limited. An exception to this trend is a theoretical study by de Jager (2014) that relies on a more realistic assumption of 30% of assets reported at FV.

3.1 Application of FVA by Nonfinancial Firms

For a typical industrial firm reporting under US GAAP, little of the firm's balance sheet will be reported at FV. Generally, only investments of surplus cash in trading securities and derivatives will use FVA at each reporting date. Other assets will be recorded at FV only when written down through the impairment process. For a similar industrial firm reporting under IFRS, in addition to the above, firms will carry biological assets at FV, as well as investment properties, PP&E, and intangible assets (if elected). Since few firms elect to carry PP&E and intangible assets at FV because of estimation challenges and investor skepticism (Christensen & Nikolaev, 2013), FVA under IFRS has little practical difference from US GAAP, except in specific industries such as farming (due to biological assets) and real estate (due to investment properties).

McDonough et al. (2020) provide descriptive statistics on the extent of FVA application in US nonfinancial firms. In 2017, nonfinancial firms in the United States reported 19% of their assets and 5% of their liabilities at FV. Most nonfinancial sectors reported only 3%–5% of their assets at FV, whereas the health care and business equipment industries reported the highest proportion of FV assets, with 44% and 20% of total assets, respectively. The health care industry also reports the highest proportion of FV liabilities, with 9% of total liabilities. Most of the FV assets for US nonfinancial firms are measured using Level 1 or Level 2 inputs, while FV liabilities are typically measured using Level 2 or Level 3 inputs.

3.2 Application of FVA by Financial Institutions

FVA affects financial institutions to a much greater extent than industrial firms due to extensive holdings of financial instruments. Derivatives and investments that are held-for-trading (HFT) are recorded at FV, with unrealized FV changes recorded in net income, while available-for-sale (AFS) investments are recorded at FV, with unrealized FV changes recorded in other comprehensive income (OCI). Investments that are held-to-maturity (HTM) are carried at amortized cost. Similarly, most loans are carried at amortized cost (except for impaired loans, which are written down to FV). While SFAS 159 and IAS 39 allow banks to report certain loans at FV, most banks do not make such elections (Laux & Leuz, 2010).

Financial institutions include bank holding companies, commercial banks, savings banks, investment banks, insurance companies, brokerage firms, and advisory and other financial services companies. We now discuss statistics from several papers based on different samples of financial institutions; in particular, we present statistics from samples of financial institutions, bank holding companies, and banks. The statistics for financial institutions are based on samples containing all types of financial services firms. While there is a considerable overlap between banks and bank holding companies, bank holding companies report consolidated statements that include non-bank subsidiaries.

For large US bank holding companies from 2004 to 2006, as an average percentage of total assets, HFT assets were 7%, AFS assets were 15%, HTM assets were 0.1%, and loans and leases were 47% (Laux & Leuz, 2010). For large US investment banks, HFT comprised 16% of total assets (Laux & Leuz, 2010). By 2017, US bank holding companies on average reported trading assets of 0.3%, AFS securities of 15%, HTM assets of 3%, and net loans and leases of 70% (McDonough et al., 2020). Notably, US bank holding companies report almost no trading assets on average in 2017, while large US banks carry 3% in trading assets (McDonough et al., 2020)—both of which are significantly lower than in the pre-GFC period. These statistics are largely similar for non-US banks reporting under IFRS.

In 2017, McDonough et al. (2020) showed that US financial institutions reported 27% of their assets at FV, which is greater than the proportion reported by nonfinancial firms (other than firms in the health care industry). Focusing on US banks, specifically, the proportion of assets carried at FV is similar to nonfinancial firms, with less than 1% HFT (3% for large banks and less than 1% for smaller banks) and 15% AFS (McDonough et al., 2020). Similar statistics are found for a longer sample period from 1984 to 2013 (Laux & Rauter, 2017). Only large commercial banks report a higher proportion of FV assets (29%) compared to the average proportions for nonfinancial firms (19%) (Laux & Rauter, 2017).

Liabilities are rarely carried at FV unless they are out-of-the-money derivatives, liabilities associated with a portfolio of assets, or liabilities designated at FV using the FV option under SFAS 159 or IAS 39. In 2017, US financial institutions reported only 3% of their liabilities at FV, which is lower than the 5% of liabilities reported at FV by nonfinancial firms (McDonough et al., 2020). US bank holding companies reported an even lower proportion of 0.5% of their liabilities at FV. While SFAS 159 and IAS 39 open the door for reporting liabilities at FV, the actual proportion remains low (Couch et al., 2017; Schneider & Tran, 2015; Xu, 2019). US banks and bank holding companies rely heavily on Level 2 inputs to measure FV assets and liabilities. In 2017, these firms used Level 2 inputs for approximately 90% of FV assets and 80% of FV liabilities.

Overall, the pure form of FVA where all assets and liabilities are carried at FV is rare. Even a sample of large US commercial banks and bank holding companies carried at most 30% of assets at FV (Laux & Leuz, 2010; McDonough et al., 2020). This percentage is much lower for small financial institutions and most industrial firms. In recent years, the percentage of assets and liabilities reported at FV has declined even for large financial institutions (McDonough et al., 2020). Level 2 inputs are the most common inputs used to measure FV assets and liabilities, while Level 3 inputs are the least common in measuring FV assets, and Level 1 inputs are the least common for FV liabilities.

4 WHAT ARE THE CONSEQUENCES OF FVA?

Financial institutions are most affected by FVA since FV applies to investment securities. FVA recognizes changes in FV in the period in which they occur. Consequently, financial statements carried at FV will generally demonstrate greater volatility in earnings and shareholders' equity (see Barth, 2004; Barth et al., 1995). Due to concerns about increased volatility, Beatty et al. (1996) found that bank investors reacted unfavorably to key events surrounding the passage of SFAS 115 (which required FVA for most investment securities). Furthermore, investors reacted positively to a perceived softening of FVA during the GFC (Bhat et al., 2011; Bowen & Khan, 2014). FVA may also impact the volatility of regulatory capital for financial firms, which could have economic costs through the increased probability of capital violations. The impact of FVA on financial statement volatility and regulatory capital are discussed in turn.

4.1 Earnings and Balance Sheet Volatility

FVA has the potential to increase volatility in financial statements since changing market conditions are reflected as they occur. In contrast, HCA inherently provides more smoothing of financial statements due to the general use of the original purchase price until disposal. Furthermore, changes to recorded values under HCA are often consistent and systematic (e.g., depreciation or amortization). FVA increases the volatility of an average bank's earnings by 26% (Barth et al., 1995). The increased volatility is theorized to come from (1) inherent volatility, (2) estimation error volatility, and (3) mixed measurement volatility (Barth, 2004).

Inherent volatility relates to changes in the underlying economic value of financial statement items. The reflection of such volatility is generally believed to provide useful information to investors; however, such volatility can be misleading for HTM assets (ECB, 2004). Furthermore, inherent volatility may be artificial for insurance companies because of the use of reinsurance and the time horizon of asset holdings, whose values are believed to be mean reverting over the long term (Trainar, 2008). Estimation error volatility stems from errors in determining FV, particularly for FVs relying on unobservable inputs (i.e., Level 3). All being equal, such estimation errors will increase volatility under FVA relative to HCA due to the lack of estimation in the latter. Finally, mixed measurement volatility results from using a mixture of FVA and HCA, which is common in practice. Using FV for assets but not for the corresponding liabilities can cause greater volatility relative to a pure FV model. Barth (2004) argues that the volatility associated with FVA is not necessarily bad since true changes in value provide information to financial statement users to assist in their capital allocation decisions. The challenge is in minimizing the volatility arising from estimation error and mixed measurement.

Using pro-forma analysis, pure FV for US banks is found to result in net income (comprehensive income) that is five times (three times) more volatile than under existing accounting rules (Hodder et al., 2006; McInnis et al., 2018). However, this incremental volatility is positively associated with market beta and the volatility of stock returns, suggesting that pure FV captures components of firm risk that are priced by investors (Hodder et al., 2006). In a simulation exercise, the ECB (2004) also finds increased volatility under a pure FV model.

Both US GAAP (SFAS 159) and IFRS (IAS 39) offer an FV option (FVO) for financial instruments. By using the FVO, companies can choose to report a financial instrument using FV rather than another measurement base such as amortized cost. The FVO is meant to alleviate the mixed-measurement volatility described above. Lending support to this idea, earnings volatility is found to decrease for financial institutions that adopted the FVO to reduce an accounting mismatch (Fiechter, 2011), and simulations provide further support (IMF, 2008). On the downside, US banks are found to use the FVO in an opportunistic way (J. S. Song, 2008). In addition, earnings volatility increased for US financial institutions that used the FVO, relative to non-adopters (Couch et al., 2017). The authors find that the increase in earnings volatility is primarily driven by firms that used the FVO for assets only, which would not necessarily mitigate the mismatch arising from mixed measurement.

Overall, academic research finds that FVA generally increases the volatility of earnings and the balance sheet, despite standard setters providing the FVO to reduce the volatility resulting from mixed measurements. In addition, contrary to the intended purpose of the FVO, some firms appear to use it in a manner that creates more, rather than less, measurement mismatch, which likely induces more volatility. Whether or not the increased volatility provides incremental information for capital market participants remains an open question. Stock market reaction studies (e.g., Beatty et al., 1996) indicate that investors view the volatility associated with FVA as negative; however, such reactions could stem from other factors associated with FVA, such as anticipated management behavior.

4.2 Regulatory Capital

Much of the contagion concerns surrounding FVA are predicated on increases in the volatility of regulatory capital, which will increase the likelihood of capital benchmark violations. Theoretical work typically presumes a direct relationship between FVs and regulatory capital; however, many differences exist in practice (see Laux, 2012). Some reporting regimes use different rules for financial reporting and regulatory capital, while other regimes start with financial reporting under US GAAP or IFRS and make adjustments to determine regulatory capital. Common adjustments include the risk weighting of assets and the exclusion of unrealized gains stemming from changes in an entity's own credit risk. In addition, unrealized losses on debt securities classified as AFS often do not affect regulatory capital unless such losses are realized or considered other-than-temporary. In summary, regulatory capital rarely has a direct one-to-one relationship with financial reporting.

In the United States, banks are governed by the following rules for regulatory capital: FV losses on HFT securities and AFS equity securities affect regulatory capital. FV losses on AFS debt securities do not affect regulatory capital unless such losses are deemed as other-than-temporary impairments (OTTIs). Similarly, losses on HTM securities, which are carried at amortized cost for financial reporting, affect regulatory capital only when impaired. Loans carried at amortized cost affect regulatory capital through the deduction of banks' loan loss provisions. Under the US implementation of Basel III, advanced approach banks are required to include unrealized gains and losses (UGL) for AFS assets in regulatory capital. Regulators have recently proposed to expand this requirement to all banks with at least $100 billion in total assets (Federal Reserve System, 2023). US insurance companies are subject to risk-based capital requirements, meaning that the capital ascribed to a given asset varies based on the credit quality of the underlying asset.

Analytical papers such as Allen and Carletti (2008) and Plantin et al. (2008) presume pure FVA and a direct relationship between financial reporting and regulatory capital—both presumptions are simplifications, as discussed above. Consequently, empirical work provides a necessary link to the impact of FVA in practice. In early work, Barth et al. (1995) evaluate the effect of carrying investment securities at FV rather than HC on regulatory capital. Using US banks from 1971 to 1990, they estimate regulatory capital and presume that FV changes have a direct impact. In this context, Barth et al. find that earnings would be more volatile and thus hypothetical violations of regulatory capital minimums would occur more frequently under FVA.

In an international context, Bernard et al. (1995) conducted an empirical study of Danish banks from 1976 to 1989 that operated in an environment where FVA is used for regulatory capital. The authors find that earnings became more volatile after incorporating FV changes; however, due to banks carrying regulatory capital in excess of required minimums, the authors assign only a 2% probability of an annual FV adjustment causing a capital violation.

Merrill et al. (2012) examine the selling behavior of US insurance companies from 2006 to 2009. The authors argue that the regulatory capital of insurers can be doubly impacted by decreasing values of investment assets: first, decreases in FV can cause direct reductions in regulatory capital. Second, since the credit quality of those investment assets has correspondingly declined, regulatory capital is further reduced. These two effects were found to motivate the selling of investment assets at distressed prices. Similarly, Ellul et al. (2011) find that regulatory capital constraints motivate US insurance companies to sell corporate bonds that have been downgraded in an effort to improve regulatory capital.

While these studies provide evidence that FVA can lead to higher regulatory capital volatility and increased likelihood of fire-sale of investments with deteriorating FVs, other studies present evidence of a limited impact of FVA on regulatory capital. When examining the 14 largest US banks in 2008, Shaffer (2010) finds that FV write-downs caused reductions to Tier 1 regulatory capital of between 0.1% and 3.9%. Dividends paid by these firms had a greater impact on regulatory capital than FV write-downs. Overall, the author's limited sample indicates FVA does not bear the primary blame for the GFC. Fiechter et al. (2017) examine the 2008 amendments of IAS 39 that allowed reclassification of FV assets to HC. Using a sample of 160 European bank holding companies, they find that “too-big-to-fail” banks made less use of this option to reclassify from FV to HC, presumably because they enjoyed political protection from regulatory pressure. However, smaller banks used the reclassification option to a greater extent to protect their regulatory capital. Hence, their results indicate that the negative effects of FVA on regulatory capital may be disproportionately experienced by smaller banks with less systemic importance.

In a more comprehensive study, Badertscher et al. (2012) test the impact of FVA on banks' regulatory capital during the GFC. The authors examine AFS and HTM securities and recognize that FV changes for AFS and HTM assets only impact regulatory capital if decreases in FV are deemed as OTTIs. While FV changes on AFS equity securities do impact regulatory capital, such securities have little impact for their sample of firms. Using 150 US banks from 2004 to 2008, the authors find that OTTIs had only a minor impact on regulatory capital. Specifically, removing the effect of OTTIs would have increased the median Tier 1 capital ratio from 9.9% to 10.0%. The authors conclude that bad debt expense on uncollectible loans had a much greater impact on capital ratios than FVA (bad debt expense moves the median capital ratio from 9.9% to 10.7%). Furthermore, the bulk of OTTIs were recorded in the second half of 2008, which weakens the argument that FVA caused the GFC since they occurred in the latter part of the crisis.

While affected firms have pressured standard setters to relax the application of FVA due in part to the impact on regulatory capital, Laux (2012) believes multiple reporting goals can be best achieved by different rules for financial reporting and regulatory capital. He states,

It is not necessary to demand adjustments in financial reporting to change how regulatory capital is derived. Given the many trade-offs that standard setters face when trying to consider the different objectives of financial reporting, such a separation can be efficient despite the higher cost involved in preparing different reports. (Laux, 2012, p. 243)

Using different sets of rules could alleviate concerns of FVA's potential effects on procyclicality and contagion while providing financial reporting that is relevant and timely. As an alternative, financial reporting rules could be changed during a crisis to alleviate procyclicality (recognizing that transparency and relevance may be weakened) (Laux & Leuz, 2010). Overall, an optimal solution that is satisfactory to all parties may not exist.

In summary, the literature finds mixed evidence on the effect of FVA on regulatory capital. On the one hand, theoretical and empirical evidence indicate that (1) FVA can lead to greater regulatory capital volatility and increased likelihood of violations and (2) firms may engage in suboptimal fire-sale of affected assets to minimize the impact of FVA on regulatory capital ratios. This strand of literature relies on the assumption that there is a direct link between FVA and regulatory reporting; however, there are many differences in the historical application of FVA for these two purposes. On the other hand, the literature documents that FVA has little actual effect on the likelihood of regulatory capital violations. This stream of literature demonstrates that other factors, such as dividend payments and loan loss provisions, have greater effects on regulatory capital, particularly for large and systemically important banks.

4.3 Other Consequences of FVA

Recent studies consider additional consequences of FVA that include its role in earnings management and regulatory capital management, its role in compensation contracting, and various economic consequences of FVA. The first stream of literature examines the role of FVA in earnings management and regulatory capital management. For a sample of US bank holding companies, Bratten et al. (2020) find that banks with greater proportions of FV assets and liabilities substitute accrual-based earnings management through loan loss provision with transaction-based earnings management through timing the realized gains and losses on investment sales. Zhao (2019) also finds that banks trade off managing earnings by using loan loss provisions versus using securitization gains (securitization gains increase with the proportion of retained interest, which is measured at FV).

Dong and Zhang (2018) examine earnings management by US banks using AFS securities. They find evidence that banks reporting UGLs through OCI use selective selling of AFS securities to manage earnings in contrast to banks that report UGLs through net income. Robinson et al. (2018) provide evidence of capital-constrained banks using Level 3 FV estimates to manage earnings to stay just above key Tier 1 capital ratios.

DeFond et al. (2020) examine the effect of FVA on the association between earnings and executive compensation (i.e., pay-performance sensitivity). They find evidence of a negative effect of FVA on pay-performance sensitivity, indicating that FVA could impair the usefulness of earnings in managers' performance evaluation. In contrast, Henderson (2022) finds that FVs are used efficiently for compensation contracting by considering the reliability of the FV estimates.

Other studies examine the relationship between FVA and dividend payout policy. E. Chen and Gavious (2016) study dividend policy changes around IFRS adoption by nonfinancial Israeli firms. They find evidence of increased dividend payouts associated with unrealized FV gains in the post-IFRS period. X. Chen et al. (2020) examine a sample of financial firms in Australia and find a positive association between FV adjustments (i.e., net UGLs) and dividend policy. These papers may indicate an unintended consequence of FVA—namely, that firms make dividend payments based on unrealized FV gains.

Other recent studies further examine the economic consequences of FVA. Chircop and Novotny-Farkas (2016) find that banks affected by Basel III requirements to include AFS investment UGLs in regulatory capital decrease their investments in risky AFS securities. These findings are in line with Basel III requirements inducing a reduction in bank risk-taking (Acharya & Ryan, 2016). Wang and Zhang (2017) study the effect of FVA on public debt structure using new debt issuances by US firms from 2008 to 2013. They find that the use of Level 2 and Level 3 FVs is associated with lower financial reporting quality, and as a result, with higher agency cost of debt.

Gopal and Gutierrez (2019) examine the effect of FVA on loan origination in syndicated loan markets in a setting where non-bank lenders use FVA and traditional banks use HCA. Relative to HCA lenders, they find that FVA lenders are more susceptible to market price changes and reduce (increase) lending to a larger extent when market prices fall (rise). Bleck and Gao (2023) examine the impact on the lending decisions of US banks when FVA directly affects regulatory capital. They find FVA may negatively affect the ex ante quality of loan origination.

Taken together, these studies demonstrate that FVA can have significant economic consequences of either a positive or negative nature. However, more research is needed to develop a better understanding of these consequences for financial and regulatory capital reporting.

5 WHAT ARE THE PRIMARY BENEFITS OF FVA?

Proponents provide three primary arguments in favor of using FVs in financial statements. First, proponents argue that FVA gives values that are current and thus provide more timely information to stakeholders. As such, FVA provides greater transparency and allows swifter corrective action to be taken to prevent crises (Acharya & Ryan, 2016; Laux & Leuz, 2009). Second, supporters of FVA argue that FV is the most relevant measurement base to financial statement users, which best achieves the stated decision-usefulness objective of the FASB and IASB Conceptual Frameworks (FASB, 2010; IASB, 2010). FVs are the most relevant measure because they contain the best and most current information for forming expectations of the future (Barth, 2006). Hence, FVA provides the best information for external stakeholders to assess the value and underlying risk of institutions. Third, by introducing greater ex post volatility to net income, shareholders equity, and regulatory capital, FVA can lead banks to reduce their exposures to more risky assets (Acharya & Ryan, 2016; Kanodia & Sapra, 2016).

Proponents further argue that the alternative, HCA, has significant flaws. HCA may artificially smooth the underlying economic reality (Schultz & Hollister, 2003; Wyatt, 1991). Furthermore, HCA allows managers to engage in gains trading (i.e., by selectively selling appreciated assets to strengthen earnings, while avoiding selling depreciated assets), which can result in poor investment choices (Ellul et al., 2011; Wyatt, 1991). While FVs may deviate from fundamental value at times of crisis, HCs, by design, do not attempt to capture fundamental value on an ongoing basis (Laux & Leuz, 2009). This criticism of HCA is echoed in discussions following the S&L crisis in the 1980s and after the 2023 US banking failures.

5.1 Value Relevance

At a conceptual level, if FV is the sole measurement basis, then “equity value is read from the balance sheet, with no further analysis needed, and the income statement reports realizations for determining value at risk” (Penman, 2007, p. 42). Thus, pure FVA would provide complete valuation information. Whether financial reporting should provide complete valuation information or provide the raw material that feeds into investors' own valuation processes is more of a philosophical question that has no clear answer at present. Nevertheless, in practice, FVA applies only to a limited number of assets and liabilities—far from Penman's scenario of comprehensive FV. Furthermore, Ball (2006) argues that “fair value incorporates more information into the financial statements” (pp. 19–20). Incorporating more information means that financial statements become more useful for assessing a company's value and for contracting with parties such as lenders (Ball, 2006).

Theoretical research on the value relevance of FVA is sparse. Using a one-period, one-asset analytical model, Luo (2019) shows that under conservative accounting, reported earnings are value-irrelevant and that informativeness increases as the volatility of reported earnings approaches the volatility of the underlying economic earnings. This finding implies greater value relevance of FVA (relative to HCA) since FVA better aligns the volatility of reported earnings with underlying economic volatility. However, Gao and Jiang (2020) show that FVA provides more information than HCA only when managers have little discretion.

Much of the empirical academic research supporting FVA draws its support from value relevance studies that demonstrate a stronger correlation between FVs (changes in FV) and stock prices (stock returns). Such studies focus on valuation as the primary purpose of financial statements. Consequently, stronger correlation between accounting data and stock values indicates increased usefulness for valuation purposes (Barth et al., 2001).

Numerous empirical studies starting in the mid-1990s have documented that FVs are superior to HCs for explaining the market value of firms. Early work explored investment assets and found enhanced value relevance for FVs. Barth (1994) finds securities' FVs are more value-relevant than HCs. Further research also finds value relevance for loans and core deposits (Barth et al., 1996) and derivatives (Venkatachalam, 1996). Beyond investment assets, FVs of pensions (Landsman, 1986) and stock options (Aboody et al., 2004) are found to be value-relevant.

Additional empirical research extending to long-lived assets provides mixed results. In an Australian setting, Barth and Clinch (1998) find that FV changes for intangible assets are value-relevant but FV changes for PP&E are not. Using a different methodology in the same setting, Easton et al. (1993) find value relevance for both intangible assets and PP&E. Liang and Riedl (2014) compare analyst forecast accuracy for investment property firms between UK firms that use FV versus US firms that use HC. They find that analyst net asset value (NAV) forecasts are more accurate for UK firms. Since investment property firms' NAVs are closely related to market value of equity, this finding supports the value relevance of FVA. Beyond value relevance, Aboody et al. (1999) find that increases in FV for PP&E are related to improvements in future operating performance. Since FVs theoretically represent the present value of future cash flows, this finding validates the predictive ability of PP&E fair value estimates.

More recently in a European setting, Liao et al. (2020) document that FVs are more value-relevant than HCs during the GFC, but not before. Similarly, Adwan et al. (2020) find that the value relevance of book equity increases during the GFC for firms with more exposure to FVA before the crisis. Bratten et al. (2016) find that UGLs recognized in OCI predict future profitability for up to 2 years ahead. This finding holds even for UGLs recognized during the GFC.

In contrast, in a US bank setting, Eccher et al. (1996) find no value relevance for FVs of deposits and only limited support for FVs of loans. Similarly, Nelson (1996) finds no support for the value relevance of deposits, loans, or long-term debt. McInnis et al. (2018) examine US banks over the period 1996–2013 and find that financial statements under full FVA are less value-relevant than those under the prevailing GAAP. They find the value relevance of FV net income improves when it is disaggregated into transitory and persistent components, suggesting that persistent FV changes are more useful to decision-makers. A possible explanation for the conflicting findings is that McInnis et al. (2018) compare full FVA with US GAAP (i.e., partial FVA) rather than comparing with full HCA.

Overall, most studies in this literature provide evidence supporting the improved value relevance of FVA relative to HCA. An exception is Gao and Jiang (2020), who show that the value relevance of FVA depends on the level of managerial discretion. We argue that this result does not demonstrate that FVs lack value relevance per se; rather, their results highlight concerns about FVs' reliability and the potential for manipulation. In Section 6.1, we provide a detailed discussion of reliability concerns. As another exception, McInnis et al. (2018) show that net income and equity measured at “full fair value” are not more value-relevant compared to current US GAAP; however, no firms use a full FV model in practice.

5.2 Risk Relevance

More recently, research has considered the relationship between FVA and various firm risk measures. The literature on the effect of FVA on earnings volatility is discussed above in Section 4.1. Here we discuss studies that focus on testing FVA's ability to assess firm risks, such as market risk, credit risk, and default risk. We seek to determine whether the literature can help us answer this question: Does FVA help external stakeholders assess a firm's risk exposure to a greater extent than HCA?

Hodder et al. (2006) find that higher volatility in full FV net income is positively associated with the volatility of stock returns, market beta, and long-term interest rate beta. In a US setting, Blankespoor et al. (2013) find that FVs provide more information for explaining credit spreads for financial instruments. Using non-US commercial banks cross-listed in the United States, Duh et al. (2012) find that FVs better capture firms' credit risks. Schneider and Tran (2015) and Fontes et al. (2018) find that FVA is associated with lower information asymmetry. Fontes et al. (2018) find that the reduction in information asymmetry is greater when banks also recognize gains and losses arising from their own credit risk and when they provide related narrative disclosures. Mohrmann and Reipe (2019) show that banks with larger proportions of Level 3 FV assets exhibit higher stock volatility and default risk. In summary, these studies show that FVA is associated with market-based risk measures, suggesting that FVA provides information relevant for assessing firm risk.

Overall, the above studies generally suggest that FVA provides decision-useful information for shareholders and creditors. FVs provide more timely information through regular updates of the value of assets and liabilities. Furthermore, stakeholders can analyze the characteristics of the FV time series to better determine firm risk characteristics. As a result of the above, more information is provided through the FV model (Ball, 2006). Nevertheless, numerous criticisms of FVA have been made, including reliability challenges, and encouragement of procyclicality and contagion.

6 WHAT ARE THE KEY CHALLENGES WITH FVA?

Despite the above evidence and widespread support from standard setters, FVA has many detractors. Beatty et al. (1996) examine stock price changes around key dates relating to the passage of SFAS 115 and find negative reactions for banks to events that increase the likelihood of passage. Chircop and Novotny-Farkas (2016) find negative market reactions around news that indicates a higher likelihood of US adoption of Basel III rules. These findings suggest investor perceptions of FVA adoption are negative overall (despite the positive effects described above).

Traditional opposition to FVA stems from poor reliability due to estimation difficulty and managerial discretion. More recently, opposition has focused on deviation from fundamental values and the self-reinforcing nature of asset write-downs due to the impact on regulatory capital (i.e., procyclicality). Former FDIC Chairman William Isaac argued that FVA was responsible for the GFC of 2007–2009: “It's due to the accounting system” (Katz, 2008). FVA required assets to be written down to “unrealistic fire-sale prices” (Katz, 2008) that were not representative of fundamental value. In particular, opponents of FVA are concerned with assets that are held for the long term (Laux & Leuz, 2009). In contrast, many argue that FVA was simply the messenger of the crisis rather than playing any causal role (e.g., Ball, 2008; Barth & Landsman, 2010; Laux & Leuz, 2010; Veron, 2008). This section will consider evidence concerning FVA's reliability and the potential for procyclicality and contagion.

6.1 Reliability

Historically, academics argued that FVA's key challenge was ensuring the reliability of FV estimates. Relative to HCs, FVs may be less reliable because values are not determined from realized transactions. Benston (2008) notes that it is difficult to establish FVs; managers must determine “imaginary prices that might be offered by hypothetical independent acquirers of its assets and liabilities who are participants in non-existent markets” (p. 103). Auditors must then find sufficient and appropriate ways to challenge and verify these values. Estimation errors can be made when FVs are required but lack traded market prices (Ball, 2006). As a specific example, Magnan (2009) points out that approximately 1 month after releasing its earnings numbers, Credit Suisse revised its 2007 operating income downward by 10% because additional work led to changes in FV estimates. This example demonstrates that estimates can be subject to a wide margin of estimation error, leading to wide swings in estimates from period to period. Financial institutions are most affected by these swings since they hold many assets and liabilities at FV, and such instruments are often complex and difficult to value.

Furthermore, managers can exercise a significant amount of discretion when they establish FV estimates. Such management discretion can be used to make FV estimates that achieve a stated goal, such as reaching an earnings target or bonus threshold. Ball (2006) believes that FVs can be more influenced by managers in illiquid markets, which negatively affects reliability, and that FVs will be more relevant than HCs only when based on observable liquid market prices. Overall, estimation errors or biases in FV estimates reduce the reliability of FVA by introducing greater uncertainty in the reported FVs or significant directional differences between reported FVs and underlying “true” FVs.

We next explore the primary approaches used in the empirical literature to investigate the reliability of FVA. The first approach employs “direct” tests of reliability by comparing FV estimates to future realized prices, subsequent revisions, restatements of FV estimates, or associations with other measures of uncertainty for assets or liabilities reported at FV. The second approach relies on the moderating effect of reliability on the value relevance of reported FVs.

6.1.1 Direct Empirical Measures of Reliability

In this section, we summarize the papers that use a direct approach to measure and test the reliability of FV estimates. Several of the papers we discuss in this section also examine the determinants of reliability, which we discuss in Section 6.1.3.

Dietrich et al. (2001) and Muller and Riedl (2002) utilize mandatory FV reporting requirements for UK investment property firms during the sample period of 1988–1996. These firms are required to annually value their investment properties and report the FV estimates on their balance sheets. Dietrich et al. (2001) compare the FVs and HCs of investment properties to actual selling prices to calculate the bias and accuracy of FVs and HCs. They find that FVs are less biased and more accurate than HCs, which indicates FVs are more reliable than HCs in this setting. They also document that FV estimates with greater perceived reliability exhibit less bias and more accuracy relative to those with lower perceived reliability.

Muller and Riedl (2002) test the relationship between the perceived reliability of reported FVs and information asymmetry in financial markets as measured by bid-ask spreads. They argue that the primary driver of information asymmetry for UK investment property firms is the uncertainty surrounding the reported FVs of investment properties since they represent most of their assets. Their findings indicate that FV estimates with more perceived reliability are associated with lower bid-ask spreads (relative to FVs with lower reliability).

Using a sample of Australian firms for the period 1981–1990, Cotter and Richardson (2002) examine the reliability of upward revaluation of non-current assets. They use the extent to which upward revaluations are subsequently reversed as a measure of the reliability of FV estimates and find that they are associated with the perceived reliability of FV estimates. Ahn et al. (2020) use the likelihood of a FV-related restatement or receipt of an SEC comment letter as measures of estimate reliability and the quality of disclosure. They find that their measures are associated with perceived reliability of FVs.

In summary, these studies develop various methods of measuring the reliability of FV estimates. These methods rely on (1) comparing FV estimates with subsequent selling prices or revisions of FV estimates, (2) FV-related financial restatements or comment letters, or (3) quoted bid-ask spreads in financial markets.

6.1.2 Reliability as a Moderator of Value Relevance

Another set of studies operate under the assumption that external decision-makers presumably discount accounting information that lacks reliability. Decision-makers would assign lower weights to less reliable relative to more reliable metrics, resulting in lower associations between less reliable metrics and decision outcomes. For example, in the value-relevance literature discussed in Section 5.1, FVs are shown to have a high degree of association with investors' firm valuations. In this context, less reliable FVs should exhibit lower value relevance relative to more reliable FVs. In this section, we discuss the studies that examine such interactions between reliability and value relevance.

Petroni and Wahlen (1995) test the incremental value relevance of FVs beyond HCs for property liability insurers prior to the 1994 adoption of SFAS 115. They find that FVs of liquid securities, such as equities and US Treasuries, are value-relevant. However, their results indicate that FVs of municipal bonds, corporate bonds, and other debt securities are not value-relevant. The authors attribute their results to the lower estimate reliability associated with instruments that are less liquid and longer term.

Empirical research has also considered differences between Level 1, Level 2, and Level 3 FVs. In testing using US financial firms, Kolev (2009), C. J. Song et al. (2010), Freeman et al. (2017), and Fortin et al. (2021) find that all three FV levels are value-relevant; however, investors discount Level 3 assets by 20%–35%. C. J. Song et al. (2010) find no difference between the value relevance of Level 1 and Level 2 FVs, suggesting investors view these instruments similarly.

Freeman et al. (2017) and Fortin et al. (2021) further investigate the effect of asset types on the value relevance of FV input hierarchies. Freeman et al. (2017) find that the relevance of Level 3 assets is lower for US banks with securitizations. Fortin et al. (2021) consider a similar question using closed-end mutual funds. They find that the value relevance of investment assets held by mutual funds varies by both investment type and FV hierarchy level. Within the same FV level, different types of investments have differing levels of value relevance, and within the same type of investments different FV levels demonstrate differences in value relevance. These findings show that FVs are not created equally; rather, value relevance differs across asset types and FV levels. The general takeaway is that FV reliability varies with the estimation difficulty for the underlying instruments. Investors discount reported FVs to a greater extent when more estimation (or greater managerial discretion) is involved in estimating FVs, either due to a lack of quoted market prices or the complexity of the instruments being measured.

Several studies find evidence of investors' skepticism of FV estimates in certain scenarios where managers may be motivated to apply FVA opportunistically, which taints the reliability of FVs. Barth et al. (1996) find investors discount the FVs of loans for banks that are less financially stable. Furthermore, Aboody et al. (1999) find that firms with high leverage have weaker relationships between revaluations of PP&E and future performance, suggesting biased estimates. Ramanna and Watts (2012) find that managers may opportunistically record goodwill impairments, which they attribute to the weak verifiability of such impairments. Consistent with opportunistic application of FVA, Robinson et al. (2018) show banks with capital ratios near regulatory benchmarks report higher gains in Level 3 assets. Moreover, they find that the value relevance of Level 3 FV assets is significantly lower for these capital-constrained banks.

Other studies provide evidence consistent with lower reliability of FV assets and liabilities reported using the FVO. Fiechter and Novotny-Farkas (2017) find FVO assets are less value-relevant than HFT or AFS assets. Examining the behavior of firms adopting the FVO for liabilities, Wu et al. (2016) find that firms with higher pre-adoption financial vulnerability are more likely to use the FVO for liabilities. Furthermore, they show that these firms experience lower stock performance after adoption.

These empirical studies generally find that the relevance of FVs decreases when greater estimation is required or when managers have greater incentive to apply FVA opportunistically. These findings demonstrate that financial statement users recognize reliability limitations with FVA and discount FVs when perceived reliability is lower.

6.1.3 Determinants of Reliability

Next, we consider studies examining the factors that affect the reliability of FVs. Cotter and Richardson (2002) find that external appraisals result in FVs that are more reliable for PP&E. Muller and Riedl (2002) find that external appraisals of investment properties decrease the uncertainty surrounding such values. Dietrich et al. (2001), Griffin (2014), and Ahn et al. (2020) examine the effect of external auditors on the reliability of FVs. Specifically, Dietrich et al. (2001) find the reliability of FV estimates improves when monitored by external appraisers and Big N auditors. Griffin (2014) finds auditors are more likely to require adjustments when FV estimates contain both input subjectivity and outcome imprecision. However, auditors tolerate potential misstatements when firms provide additional disclosures. Ahn et al. (2020) show that task-specific auditor expertise improves the quality of FVA, particularly for Level 3 inputs. Overall, the increased usefulness of FVs in light of independent appraisals and auditors suggests that investors discount management-prepared FVs when the potential for bias exists.

Using a sample of banks and insurance companies, Chung et al. (2017) document evidence suggesting that firms are aware of the discount applied to Level 3 FVs. They find firms having more Level 3 assets and liabilities disclose more information about their FVs, which may increase investor confidence in those estimates. They also find that firms with more opaque FV estimates are more likely to provide voluntary FV disclosures. These additional disclosures reduce information risk in Level 3 estimates and improve value relevance. Robinson et al. (2018) provide similar evidence of additional disclosures to mitigate the discount applied to Level 3 FVs.

Bhat and Ryan (2015) show that banks' own market and credit risk modeling improves the value relevance of FV gains and losses. They also find that the improvements are greater when the underlying instruments are less liquid. These results suggest that firms are aware of the reliability concerns surrounding FV estimates and that they can increase reliability of their FVs by actively modeling the underlying risk and hence reducing the potential estimation error during periods of turbulent markets.

C. J. Song et al. (2010) find that strong corporate governance reduces the discount assigned to FVs by investors, particularly for Level 3 assets. Siekkinen (2017) shows that board independence and gender diversity have a positive impact on the value relevance of Level 3 FVs. Chung et al. (2021) show that the value relevance of gains and losses from the FVO are moderated by the level of institutional ownership—a proxy for external scrutiny. Relatedly, Fiechter and Novotny-Farkas (2017), Yao et al. (2018), and Liao et al. (2020) find cross-country institutional differences affect the reliability of FVs. Fiechter and Novotny-Farkas (2017) show that FVO assets are less value-relevant in countries with bank-based economies (e.g., Austria and Germany) than in those with market-based economies (e.g., Australia and United Kingdom). Using banks in 22 countries, Yao et al. (2018) find that FVA improves earnings persistence; however, this improvement holds for Level 2 and Level 3 FVs only in countries with strong legal enforcement and audit environments. Liao et al. (2020) provide evidence that cross-country differences in accounting enforcement affect the value relevance of FVA relative to HCA.

Estimate reliability remains a key concern with FVs. Academic research generally finds that reliability represents a larger problem for assets and liabilities that do not have traded values in active markets (i.e., Level 2 and 3 FVs). External validation of FV estimates or stronger governance may alleviate reliability concerns. In recent years, attention has shifted away from assessing the reliability of FVs to concerns about procyclicality and contagion.

6.2 Procyclicality and Contagion

The GFC of 2007–2009 moved the focus away from criticizing the reliability of FVs to concerns about procyclicality and contagion. Procyclicality of FVA is typically described as exacerbation of boom-bust cycles (e.g., Adrian & Shin, 2010; Novoa et al., 2009; Plantin et al., 2008). In boom times, unrealized FVs increase, which leads to higher equity and lower leverage based on market values. The decreased leverage allows firms to acquire additional assets to move leverage back to a target level. The additional purchases cause asset prices to rise, which perpetuates the cycle. In a bust cycle, falling asset prices cause lower equity and higher leverage. The higher leverage necessitates asset sales or recapitalization. The asset sales cause further asset price drops, leading to a feedback effect that can cause a crisis. Further affecting price drops can be illiquidity: in periods where falling prices cause asset sales, the preponderance of sellers leads to a lack of potential buyers.

In contrast to procyclicality, contagion effects stem from asset prices deviating from fundamental value (Cifuentes et al., 2005; Laux & Leuz, 2009). In times of crisis, a firm may be required to sell assets at prices that are below fundamental value; these “fire-sale” prices then become the reported FVs for other firms (Shleifer & Vishny, 2011). The low FVs may cause firms to violate regulatory capital requirements. Thus, one firm's distress gets transferred to numerous other firms that carry the same or similar assets, causing contagion. Such distress sales that occur during a time of crisis can be accompanied by a tightening of credit (Brunnermeier, 2009), which can exacerbate financial distress and lead to more distress sales. While the very definition of FV considers only “orderly” transactions (IFRS 13, IASB 2011, para. 9)—which would typically exclude fire sales—firms (or their auditors) may be hesitant to ignore recent transactions when determining FV. The exclusion of distress sales when determining FV was made explicit by the FASB's staff position issued in April 2009 (FSP FAS 157-4, FASB, 2009). Investor reaction to FAS 157-4 is discussed below.

The debate about whether FVA creates or exacerbates procyclicality and contagion is ongoing with the academic literature finding mixed evidence. First, we discuss studies providing support for the claim that FVA causes procyclicality and contagion, including papers documenting investors' reaction to FAS 157-4. We then discuss the studies that dispute the causal effect of FVA on procyclicality and contagion.

6.2.1 FVA Leads to Procyclicality and Contagion

Plantin et al. (2008) use theoretical modeling to analyze the effects of FVA. In their setting, FVA causes additional price volatility, which can lead to procyclical effects on asset prices. These effects are strongest for instruments that have a long duration, are illiquid, and are senior, which are characteristics that tend to apply to the assets of banks and the liabilities of insurance companies. They assume that financial institutions are run by managers with shorter horizons than the duration of their assets and identify managerial myopia as a key mechanism through which FVA causes additional market volatility. de Jager (2014) provides additional theoretical support for the procyclicality of FVA but emphasizes that the role of FVA in distress sales is likely to be dampened by regulatory flexibility during crises. Finally, using theoretical modeling, Allen and Carletti (2008) demonstrate that contagion can result from using FVA during a financial crisis. When markets are illiquid, prices reflect the available liquidity rather than future cash flows and thus deviate from fundamental value. The depressed FVs can cause insolvency, which is inconsistent with future cash flow analysis of the assets.

Turning to empirical work, Bhat et al. (2011) empirically test for the presence of procyclicality using a sample of US banks from 2006 to 2010. The authors conjecture that, if procyclical, price declines should be related to increases in asset sales. For non-agency mortgage-backed securities (MBS), the authors find evidence of a procyclical relationship; however, the relationship has a relatively small economic magnitude and would be unlikely to lead to significant consequences. Supporting the notion that FVA causes procyclicality, the authors find that procyclicality is reduced following the passage of FAS 157-4 in April 2009 that changed the applicability of FVA. Finally, banks holding certain assets showed positive stock reactions to the FAS 157-4 rules changes, suggesting that investors view softening of FVA rules as value-increasing (Bhat et al., 2011).

Boyson et al. (2010) use a sample of hedge fund index returns and find evidence of contagion in periods of poor returns. Similarly, Khan et al. (2019) find evidence of contagion for US banks during periods of poor performance. During periods of illiquidity, the contagion effect is stronger for banks with a greater proportion of their balance sheets at FV. Khan et al.'s results provide support for FVA leading to contagion during a period of financial crisis.

Using a sample of US insurance companies holding non-agency residential MBS from 2006 to 2009, Merrill et al. (2012) find evidence that FVA can lead to sales of assets at fire-sale prices. They believe that the combination of FVA, impairment accounting, and credit-sensitive regulatory capital requirements motivates firms to sell low-quality assets at prices that can be below fundamental value. Such sales can cause procyclicality under FVA and contagion by reducing the FVs of assets for other firms. Using a similar sample of US insurance companies, but considering the period from 2001 to 2005, Ellul et al. (2011) assess how insurance companies respond to their corporate bond assets being downgraded. They find evidence that insurance companies can be motivated to sell assets at fire-sale prices when constrained by regulatory capital. The fire-sale prices, which would be used for determining FVs at firms holding similar assets, gradually recover over a 35-week period as investors not facing capital constraints acquire the assets.

Bowen and Khan (2014) study investor reactions to events that indicate a loosening or tightening of FV application to banks during the GFC of 2007–2009. When issued, the revised guidance allowed firms to avoid using FV when markets were illiquid or sales were distressed. The authors generally found that investors responded positively to softer FVA rules, particularly for banks with a higher proportion of illiquid assets. Using a sample of 302 banks from 39 countries reporting under IFRS, Bischof et al. (2023) study the introduction of the reclassification option for financial assets during the GFC. The IASB amended IAS 39 in October 2008 to allow firms the option of avoiding FVA for certain financial assets. In contrast to Bowen and Khan (2014), Bischof et al. (2023) find that investors reacted negatively to the IASB amendment announcement and to bank announcements stating that they would use the option. However, the reactions were positive for banks that simultaneously announced the use of government support.

Kolasinski and Yang (2024) also exploit the GFC of 2007–2009 to empirically test Plantin et al.'s (2008) prediction that managerial short-termism is a key mechanism for the role of FVA in procyclicality and contagion. Myopic managers with incentives to keep stock prices high in the short term may prefer to engage in feedback trading (i.e., to sell their assets early with a certain loss rather than face the possibility of having to record significantly more unrealized losses based on the last transaction during the period). Supporting this hypothesis, Kolasinski and Yang (2024) document an association between managerial myopia and the likelihood of selling assets into negative liquidity shocks, and the association gets stronger for financial institutions carrying more assets that are prone to feedback trading.

Khan et al. (2019) find that bank systemic risk increased following the adoption of SFAS 115, which required AFS securities to be recognized at FV. Furthermore, he finds that systemic risk decreased when regulators excluded UGLs on AFS from regulatory capital. Consistent with the market reactions documented in other studies, these results suggest that FVA increases systemic risk through the inclusion of volatile FV changes in regulatory capital.

6.2.2 FVA Does Not Lead to Procyclicality and Contagion

While many studies support the procyclical nature of FVA, other studies provide evidence to the contrary. Ball (2008), Veron (2008), and Barth and Landsman (2010) argue that FVA was simply the scapegoat for a financial crisis that was brought on by excessive risk-taking by financial institutions. They all conclude that FVA had little or no effect on the financial crisis. Ball singles out leverage as a key area of concern and argues that more, rather than less, FVA may be desirable. He states, “Abandoning fair value accounting is equivalent to ignoring market prices” (Ball, 2008, p. 4). Veron (2008) adds that no viable alternative exists that would maintain the positive characteristics of FVA while minimizing potential problems. Furthermore, there is no evidence that the financial crisis would have been less severe under HCA (Laux & Leuz, 2010). To summarize, a number of influential academics argue that FVA does not cause the procyclical effects commonly ascribed to it.

Supporting this argument, Laux and Leuz (2010) analyze a sample of large US banks during the financial crisis and find that banks doubled the amount of Level 3 assets from 7% to 14% during the financial crisis. The increase in Level 3 FVs could indicate that banks used internal valuation models when they believed market values deviated from fundamental value. Using a sample of 150 US bank holding companies from 2004 to 2008, Badertscher et al. (2012) find only limited evidence that FVA led to asset sales during the financial crisis. In particular, they find no evidence of sales at “fire-sale” prices. Furthermore, any sales that actually occurred did not lead to contagion, since industry-wide sales were unaffected.

Xie (2016) uses a database of banks' residential mortgage approval decisions to find no evidence that FVA leads to procyclical lending decisions. Using a sample of US banks, Amel-Zadeh et al. (2017) show that the procyclicality of bank leverage is largely driven by regulatory leverage constraints rather than FVA. Kolasinski and Yang (2024) also find evidence that suggests regulatory capital requirements play a significant role in asset fire sales.

Using a sample of insurance companies, Khan et al. (2019) find firms that are required to measure securities at FV on a recurring basis recognize timelier OTTIs versus firms primarily using HCA. Since timelier recognition of impairments improves transparency and reduces systemic risk, this evidence is contrary to the hypothesis that FVA exacerbates procyclicality and leads to contagion.

Laux and Rauter (2017) examine the determinants of procyclical book leverage for a sample of US commercial and savings banks and find that bank total asset growth and US GDP growth are positively related to bank leverage. They find little evidence supporting the hypothesis that FVA causes procyclical leverage. Furthermore, they consider the role of banks' business models, which are inherently procyclical. Banks provide loans and collect deposits; thus, the inflows and outflows of deposits are directly correlated with asset growth and leverage. Banks are likely to increase their leverage and lend more during periods of high GDP growth since loans are more profitable and less risky during those periods. Their findings raise the possibility that the association between FVA and procyclicality may result from banks' inherent role in the economy (i.e., since banks' balance sheets and leverage increase with GDP). Additional research is needed to fully understand the implications of banks' business models on FVA.

In summary, theoretical papers that demonstrate the procyclical/contagious properties of FVA presume a direct relationship between accounting values and regulatory capital. Such a direct relationship does not exist in practice. Empirical papers find mixed evidence for investors' reactions to rule changes that soften the application of FVA. While numerous academics (e.g., Ball, 2008; Veron, 2008) argue that FVA bears no blame in the financial crisis, mixed empirical evidence is found in papers that assess whether FVA led to procyclicality/contagion in banks (e.g., Badertscher et al., 2012; Bhat et al., 2011; Khan, 2019; Laux & Rauter, 2017). Even if FVA were procyclical, these papers find relatively small magnitudes to the FVA effect. In testing of US insurance companies, evidence of fire-sale prices is found under capital-constrained conditions (Ellul et al., 2011; Merrill et al., 2012). Such fire sales are consistent with procyclical properties of FVA. Overall, numerous studies have investigated whether FVA has procyclical/contagious properties, but additional study is needed to reach definitive conclusions. Furthermore, even if conclusive evidence is found that demonstrates FVA's negative characteristics, little attention has been devoted to finding a viable alternative.

7 FURTHER STUDY

While the benefits and consequences of FVA have been studied extensively, numerous unaddressed questions remain. In this section, we provide a brief discussion of the areas we believe are in need of further research.

7.1 Procyclicality, Contagion, and When Markets Are Not Orderly

Laux and Leuz (2009) identified several areas that required additional work, including whether FVA contributed to the GFC. Researchers have attempted to answer this question, but more work is needed to clearly understand if and how FVA contributed to the financial crisis. What are the precise mechanisms through which FVA leads to contagion in a financial crisis? How exactly would HCA (or other alternatives) help in avoiding or mitigating crises? The S&L crisis in the 1980s, the GFC of 2007–2009, and the 2023 US banking failures all came after significant and rapid changes in macroeconomic conditions; however, much of the FVA literature abstracts away from macroeconomic effects when considering the role of accounting in crises. More research is needed to understand whether accounting choices have incremental effects after considering macroeconomic variables. For example, during the 2023 failure of SVB, many blamed HCA for helping the bank hide its unrealized losses until it was too late. Little consideration has been given to the potential impact had FVA been used for the assets in question. Would FVA have exacerbated the problem by creating contagion effects since many other banks held similar assets on their balance sheets?

Moreover, much of the extant research fails to consider the role of banks' business models in the procyclicality of bank leverage, for which FVA is blamed for aggravating. For example, banks play a crucial role in the business cycle through their lending decisions. Bank lending generally expands during a boom because it is less risky and more rewarding to lend, and contracts during a bust because it is more risky and less rewarding to lend. This can create a mechanical relationship between bank leverage and the FVs of assets and liabilities on banks' balance sheets. While Laux and Rauter (2017) consider the role of the business cycle, more research is needed.

Under the current exit value−based definition of FV (SFAS 157 and IFRS 13), FV measurement requires estimation of the market values of assets if they are not actively traded or if markets are deemed disorderly. When estimating the exit value for assets, firms should consider the best possible use for the assets by the firm or a third party. However, managers may struggle to estimate the value of their assets from a third-party perspective, particularly for nonfinancial or long-duration assets. In this scenario, managers may be forced to rely on value-in-use when estimating asset FVs. We found no studies exploring the extent to which firms rely on value-in-use as opposed to exit value when estimating FVs. We believe such research will contribute to the literature on the relevance and reliability of FVA and inform standard setters about the feasibility of the current definition of FV.

7.2 FVO

The limited number of existing studies on the FVO provide mixed evidence on its effectiveness in reducing measurement mismatch and hence earnings and balance sheet volatility. Further research is needed to fully understand the extent and nature of how the FVO is applied. How extensively is the FVO used? Does the application of the FVO vary systematically across firms? To what extent is the FVO used opportunistically as opposed to increasing informativeness? Are investors able to undo the effects of opportunistic FVO use?

7.3 Earnings and Balance Sheet Volatility

The literature on the effect of FVA on the volatility of financial statement elements is mostly focused on earnings volatility. While the evidence on FVA's effect on earnings volatility is mixed and requires more research, there are several other potentially fruitful avenues for future work. Researchers could examine the effect of FVA on the volatility of other financial statement elements and metrics that may be based on those elements. For example, how does FVA affect the volatility of assets, liabilities, and ratios such as the current ratio? The volatility of these measures can have significant implications for firms since ratios are often used in debt contracting. For instance, would FVA increase the volatility of the current ratio, which could lead to firms holding more short-term assets to avoid covenant violations? If this is the case, does FVA improve firm resilience or create inefficiencies since, ceteris paribus, short-term assets may provide lower expected returns relative to long-term assets?

In addition, the question of whether FVA-induced financial reporting volatility is reflective of underlying economic realities and hence increases the informativeness of financial statements remains unresolved. Most of the existing research focuses on excessive downside volatility during crises, such as the GFC. Future researchers could examine the effect of FVA during normal times. Does it affect financial reporting volatility during periods of economic tranquility? What about during economic euphoria (i.e., bubbles)? In general, financial statements accurately reflecting fluctuations in companies' underlying economics may simply be bringing the volatility to the surface. The challenge is that market values can significantly diverge from fundamental values on a short-term basis. However, HCA is not immune from this problem since costs will often diverge from firm fundamentals as time moves away from the original transaction date. Future research could address these concerns by examining how financial reporting volatility under FVA and HCA maps to volatility in the underlying economic fundamentals. This line of research can also contribute to the question of whether FVA contributes to contagion during crises.

7.4 Risk Relevance

Research on risk relevance of FVs is relatively recent and includes only a few studies. We believe this is one of the most fruitful avenues for future research. FVs of assets and liabilities are closely tied to the underlying risks in those instruments, including firm-specific and macroeconomic risks. For example, the FV of an investment portfolio of corporate bonds may fluctuate due to changes in the credit risk of the individual bond issuers, due to changes in market interest rates, or due to changes in the liquidity characteristics of the bonds affecting the investors' abilities to buy/sell the bonds without significant price impact. Future research could examine the extent to which FVA reflects the above and other risks facing the reporting firm and to what extent FVA affects ex ante risk-taking behavior.

The relationship between FVA and credit risk warrants further investigation. Much of the literature focuses on the relevance of FVs for equity investors, while credit markets are significantly larger in magnitude. Do FVs provide superior information to HCs for assessing an entity's ability to repay? How often and in what capacity are FVs used in contracting with the providers of debt capital?

7.5 Disentangling Relevance versus Reliability

Much of the FVA literature deals with relevance versus reliability, which are the two fundamental characteristics of accounting information. However, the methodology used in most studies to test the reliability of FVA cannot fully disentangle reliability from relevance. For example, the weak association between market value of equity and Level 3 FVs could be driven by lower perceived reliability or lower relevance. This is not a criticism of any particular study but rather a comment on the difficulty of examining reliability and relevance in isolation. Relatively few studies (discussed in Section 6.1.1) have attempted to directly test the reliability of FVA by using realized prices when assets are subsequently sold or other market-based measures of reliability such as bid-ask spread. We encourage future researchers to identify such settings where they can study only one of the two fundamental characteristics in isolation. For example, ceteris paribus, stock price volatility or analyst forecast dispersion could be used as proxies for the perceived reliability of financial statements. However, it remains difficult to rely on market-based measures to isolate the effects of reliability since market participants make decisions based on all available inputs. We believe experimental research may be a fruitful avenue for this testing since experiments could be designed to hold one of the effects constant while varying the other.

Recent studies have examined many of the research questions posed by earlier surveys of the FVA literature. Landsman (2007) suggests that cross-country institutional differences are likely to affect the relevance and reliability of FVs, and several studies discussed in this review have provided insight. However, more work is needed to reach consensus and to understand the precise mechanisms through which institutional differences affect FVA. For example, future researchers could examine whether cross-country institutional differences directly affect the quality of FV estimates or whether they influence investors' abilities to process FV information.

7.6 Insurance Companies

Much of the existing research has focused on FVA's impact on banks, with limited attention being directed toward insurance companies—even though the impact of FVA can be heightened for these firms due to the long time horizon of their assets and liabilities (Trainar, 2008). Additional research could determine whether findings using banks extends to insurance companies and whether FVA's challenges affect insurance companies to a greater or lesser extent.

7.7 Alternatives to FVA

FVA is often criticized without providing a superior alternative accounting treatment. In general, two measurement options exist: (1) HC (which generally includes a concept that reduces the value down to FV if impaired) and (2) FV. Future research could develop new measurement concepts that share in the benefits of FVA (such as high relevance) while limiting the downsides (such as the potential for opportunism). We note that financial firms often use different measurement approaches for financial reporting versus for determining regulatory capital. Could a single measurement base exist that satisfies the needs of both sets of users? Such a measurement base would reduce costs and enhance comparability across jurisdictions. As an example, accounting for investments in long-term bonds using amortized cost has been criticized for delaying loss recognition when market interest rates increase and sale is likely. Similarly, using FV has been criticized for increasing earnings and asset volatility when the asset in question may be held to maturity. Could a measurement middle ground exist that minimizes the criticisms levied against both HC and FV?

8 CONCLUSION

The use of FV as a measurement base for financial reporting has increased dramatically over the past several decades. While applied principally to financial instruments, FVA may also apply to nonfinancial assets such as investment properties and biological assets. Furthermore, impairment testing often uses FV as an upper bound. Due to the limited applicability of FVA, the average industrial firm will report only a small portion of its balance sheet at FV, while the average financial institution will record a greater proportion. FVA gained momentum due to the perceived failings of HCA that delayed loss recognition. However, FVA has come under intense scrutiny since the GFC of 2007–2009, with FVA being blamed for causing or aggravating the financial crisis through procyclical and contagious properties.

Historically, the debate surrounding FVA centered over the trade-off between relevance and reliability: FV was demonstrated to be more useful to investors for capital allocation decisions (i.e., greater relevance) but less reliable because of estimation error and the potential for manipulation. Recent studies have found the reliability of FVA is influenced by factors including governance, management incentives, external assurance, and internal risk modeling. The debate over the role of FVA and HCA during crises and episodes of bank failure is still ongoing. Commentators blame both FVA and HCA for compounding crises at different times. Studies have provided evidence that FVA may have played a role in worsening the GFC of 2007–2009, while others have argued FVA was just the messenger. HCA was blamed during the S&L crisis in the 1980s and during the 2023 US bank failures.

FVA remains firmly entrenched in GAAP throughout the world. The issue of whether the information environment has improved with FVA continues to be controversial. While academic research has explored many aspects of FVA, numerous questions remain unresolved. Researchers have made significant progress by improving our understanding of the role of FVA in providing relevant and reliable information to external decision makers, in aggravating or mitigating crises, and in affecting firms' economic decisions. However, the need for additional research remains. As Laux and Leuz (2009) state, “In sum, the fair-value debate is far from over and much remains to be done” (p. 833).

  • 1 The list of FV standards issued by the IASB and the FASB in the preceding paragraph are not intended to be comprehensive; rather, they include the primary FV standards that affect financial institutions.
  • 2 See McDonough et al. (2020) for a detailed discussion of the history of fair value accounting.
  • 3 Quoted prices include bid-ask quotes in dealer markets where the dealers stand ready to buy (sell) at the bid (ask) prices (SFAS 157, FASB 2006, para. 31).
  • 4 In some cases, estimated FV may be entity-specific due to the requirement under IFRS 13 for the FV of nonfinancial assets to represent the “highest and best use” (IASB 2011, para. 27). Such uses may be specific to a particular entity.
  • 5 For example, investment assets may be carried at FV while the borrowings to support the assets may be carried at HC.
  • 6 Publicly traded German banks that were required to use IFRS for financial reporting were allowed to use German local GAAP (HGB) for regulatory purposes for a transitory period of 5 years upon IFRS adoption.
  • 7 Advanced approach banks are large, internationally active banks with at least $250 billion in total consolidated assets or at least $10 billion in total on–balance sheet foreign exposure.
  • 8 Badertscher et al. (2012) exclude HFT because such securities are expected to be sold in the short term, so procyclical effects are unlikely. Furthermore, agreement generally exists that trading securities should be carried at FV (Laux, 2012).
  • 9 Recent surveys of the key arguments and related research surrounding FV include Landsman (2006, 2007), Barth (2007), and Acharya and Ryan (2016).
  • 10 “The objective of general-purpose financial reporting is to provide financial information about the reporting entity that is useful to existing and potential investors, lenders and other creditors in making decisions about providing resources to the entity” (IASB, 2010, OB2).
  • 11 While industrial companies do not often hold as great of a proportion of assets reported at FV as financial institutions, such assets (such as real estate or PP&E) may be more difficult to value than financial assets.
  • 12 Regulatory capital requirements are credit sensitive when the capital provided by an asset class varies by the credit ratings of the underlying securities.

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