06 janeiro 2015

Ilusão da comparabilidade e "auditibilidade" nas Demonstrações Financeiras

Tom Selling, membro do Standing Advisory Group do PCAOB, argumenta que não há comparabilidade e "auditibilidade" das demonstrações financeiras. A argumentação é embasada com um exemplo sobre o teste de impairment. O texto é excelente.

My inspirations for this post are the maiden speech of the SEC’s new chief accountant James Schnurr, and the joy of paying only $2.02/gallon at the pump.
As for Mr. Schnurr, I plan to dissect his remarks more fully in a blog post to come, but for now I’ll confine my review to his mentioning comparability of financial statements no less than seven times, e.g., “Comparability is a hallmark of U.S. financial reporting…”
As to the relevance of my satisfying gas station experience, the financial reporting implications of the 50% decline in oil prices over the past six months make for a timely illustration for why Mr. Schnurr’s statements about comparability are nothing more than hot air.

Why Comparability of Financial Statements is an Illusion

There are many, many reasons why financial reports are not comparable.  Tops on my list, though somewhat off topic, is the absence of adjustments for inflation.  No respectable economist would ever dream of comparing trends in costs or revenues without adjusting for inflation; so it really irks me that in accounting, we never adjust for inflation.
Truly, by ignoring the necessity for inflation adjustments, it makes the accounting profession (including our august chief accountant) look like a bunch of simpletons.  Some will argue over implementation details, but accounting for inflation is no harder or easier than dealing with multiple currencies (yet, see here and here for how the FASB managed to screw that up, too).
Adjustments for inflation are merely a pre-condition for making comparisons. Let’s get back to the drop in O&G prices that have made many of us joyous, but must surely frustrate the managers of companies whose recent investment decisions were predicated on higher and steadier prices.  These managers have many hard operational and strategic choices to make; and to make matters worse for them — e.g., the threat to their earnings-based bonus checks — they also have to deal with the accounting question of asset “impairment.”


But seriously, the above example plainly illustrates that even the most assiduous application of GAAP will not produce comparable information.  Impairment is just one of many examples that we can all think of.

Why Financial Statement Audits are an Illusion
Which brings me to the second, and main point that I want to make: the impairment test is not auditable.  


Financial accounting standards like the one for the impairment of long-lived financial assets defeats, instead of promotes, comparability.  And, especially when facts and circumstances indicate to any extent that the past is not indicative of the future, not even the most independent and technically competent auditor on the planet could reliably assess the “reasonableness” of management’s estimates of variables like future oil prices.


Nothing I have written here concerning the lack of comparability of financial statements is something that Mr. Schnurr doesn’t already know.  Instead of disingenuously blowing smoke about comparability being a hallmark of U.S. GAAP he should at least be raising real issues and getting the PCAOB and FASB to actually do something about them.

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