Volume 12, No. 13


The FIN 46 Way To Plumper Balance Sheets  Enron showed the world the power of an idea: if investors can't see it, they can't ask you about it, - the it being assets and debt. That company nearly perfected the art of off-balance sheet financing, and its demise led to a rapid reconsideration of some of the accounting rules for consolidated financial statements. The reconsideration led to last January's issuance of FASB Interpretation No. 46, Consolidation of Variable Interest Entities. Call it FIN 46 for short. Call it a principles-based standard as well: judgment aplenty is required to evaluate whether or not an outfit is a variable interest entity, or who is its primary beneficiary. Those determinations make the critical difference between assets and liabilities remaining off-balance sheet or being displayed in full sunshine. The standard was not well-received by financial statement preparers, and their repeated howls for more guidance have been ultimately satisfied: on October 9th, the FASB postponed FIN 46's implementation for another three months. Superficially, it appears that the FASB caved to pressure, but the underlying reason is more practical: the SEC is not sure it's ready to handle the wave of new registrants or changes in registration that FIN 46's application could trigger. Meanwhile, investors and analysts still grapple with foggy disclosures about the expected effects of FIN 46 adoption and uneven comparables: some firms have adopted it while others are waiting until the last minute. This report is a review 10-Q MD&A discussions of the issues surrounding FIN 46's application for S&P 500 companies.

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