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- #6,642
- Edited 6:19pm May 27, 2019 5:06pm | Edited 6:19pm
- | Commercial User | Joined Dec 2014 | 14,164 Posts
- #6,643
- May 27, 2019 9:39pm May 27, 2019 9:39pm
- | Commercial User | Joined Dec 2014 | 14,164 Posts
https://newsroom.proaurum.de/the-war-on-cash-part-ii/
Economic, social and human cost
Beyond privacy, there is also widespread concern over the economic impact of a fully cashless system. For one thing, as citizens slowly become exclusively dependent on big banks and card companies the systemic risk to the wider economy spikes. But it goes further that that too. Without the option to keep some cash outside the banking system and retain some degree of financial flexibility, banks have the potential to essentially keep their clients hostage. Bail-in scenarios and deposit “haircuts”, allowing distressed banks to directly take funds from their clients’ accounts, a scenario we saw in Cyprus in 2013, are instantly simplified. Good old-fashioned bank runs are all but eliminated as leverage, while policies like NIRP and ZIRP face significantly lower obstacles, as without the option to take cash out of the system, the banks can easily pass down the associated costs to the clients.
https://newsroom.proaurum.de/wp-cont...-1-330x450.jpg
Capital controls also become much easier to comprehensively enforce, while their impact is multiplied. These measures were already proven catastrophic in Greece, where citizens had to live for over 3 years with an ATM withdrawal limit of EUR60 a day and draconian restrictions on payments abroad. Businesses were put under immense pressure, unable to pay their international suppliers without special permission, while elderly citizens formed endless lines in front of ATMs to receive their pensions in the allowed increments and many struggled to pay for their daily needs. And yet, disastrous as the policy was for the public, their predicament would have been infinitely more severe if Greece did not have a solid cash-loving tradition. The small Mediterranean nation holds the second place (tied with Cyprus) among EU members with the highest share of cash transactions, while due to the country’s history, citizens are inclined to keep significant amounts or parts of their savings stored at home, something that helped soften the impact of the capital control measures.
Furthermore, there is another important risk as the war on cash escalates, affecting significant parts of the population, namely the threat of financial exclusion. In most Nordic countries, among the first and most eager to adopt the move from cash to electronic money, pensioners have seriously struggled with the shift, as they do not use the internet or have access to online banking. In Norway, the conversion to cashless bank branches has left many towns without a single bank, the Swedish National Pensioners Organization has stressed that 1 million people in the country are not ready for cashless transactions, while Denmark’s DaneAge Association, representing more than 750,000 senior citizens, has strongly criticized the limits on cash-based payments. Apart from the elderly, those at the lower end of socio-economic pyramid are also victimized by these policies. The war on cash effectively ensures that those without access to baking services, those living in poverty and the homeless population is banned from participating in the economy and by extension socially marginalized even more.
https://newsroom.proaurum.de/wp-cont..._2-600x361.jpg
Once again, let us underline the practical and realistic nature of this threat, by recalling another real-life example, this time from India. Following the Indian government’s decision in 2016 to withdraw the very widely used 500- and 1000-rupee notes from circulation, a policy that we know now has spectacularly failed in its objectives, the disastrous implementation of the law saw chaos reign all over the country and the economy in disarray. Business operations were disrupted, employees went unpaid and even everyday transactions, as simple as grocery shopping, became a formidable challenge. During this mayhem, tens of millions of Indians, having no access to banking services and most of them from the lowest economic strata, found themselves without the means to pay for their basic needs. As their money wasn’t accepted anymore, they were deprived of bare necessities, including food, essential medicine and medical services. The situation was so dire, that dozens of people died. This even included children and infants that were refused treatment in hospitals, as the staff would not accept their families’ banknotes as payment.
The way forward
Given the aggressive and persistent steps that governments, institutions and banks have taken so far to annihilate cash, it is reasonable to expect the pressure to keep building up. However, while the fate of physical banknotes might be already sealed, it definitely doesn’t mean that investors, savers and everyday citizens have no moves left.
The technological progress that has allowed this shift away from individual financial sovereignty to take place to begin with is now providing ways to reclaim it. The rise of cryptocurrencies and of decentralized systems that protect their users’ privacy and eliminate the need for a central authority have already shown great promise. And while their disruptive potential might indeed be considerable, their real strength arguably lies in the fact that they provide more choices to consumers, adding options, instead of limiting them and allowing free, voluntary engagement with different ideas and concepts, instead of forcing people to use a single system.
While new technologies might one day prove valuable tools to resist centralization and to keep transactions outside the banking system, when it comes to saving and storing value, the solution has always been there. As cash and the relative autonomy that came with it quickly fades, the role of precious metals becomes more important than ever. Physical gold and silver, stored outside the banking system and in a stable jurisdiction, such as Switzerland, is an essential step towards limiting one’s exposure to these risks, preserving wealth and safeguarding one’s autonomy and financial independence. Combined with the potential of new blockchain-based technologies and the capacity for the digitalization of real assets, gold can even be used in a decentralized trading platform, where it can be traded outside the banking system, offering the capacity to overcome controlling governmental pressures and reclaim privacy rights.
Claudio Grass, Hünenberg See, Switzerland
www.claudiograss.ch
Economic, social and human cost
Beyond privacy, there is also widespread concern over the economic impact of a fully cashless system. For one thing, as citizens slowly become exclusively dependent on big banks and card companies the systemic risk to the wider economy spikes. But it goes further that that too. Without the option to keep some cash outside the banking system and retain some degree of financial flexibility, banks have the potential to essentially keep their clients hostage. Bail-in scenarios and deposit “haircuts”, allowing distressed banks to directly take funds from their clients’ accounts, a scenario we saw in Cyprus in 2013, are instantly simplified. Good old-fashioned bank runs are all but eliminated as leverage, while policies like NIRP and ZIRP face significantly lower obstacles, as without the option to take cash out of the system, the banks can easily pass down the associated costs to the clients.
https://newsroom.proaurum.de/wp-cont...-1-330x450.jpg
Capital controls also become much easier to comprehensively enforce, while their impact is multiplied. These measures were already proven catastrophic in Greece, where citizens had to live for over 3 years with an ATM withdrawal limit of EUR60 a day and draconian restrictions on payments abroad. Businesses were put under immense pressure, unable to pay their international suppliers without special permission, while elderly citizens formed endless lines in front of ATMs to receive their pensions in the allowed increments and many struggled to pay for their daily needs. And yet, disastrous as the policy was for the public, their predicament would have been infinitely more severe if Greece did not have a solid cash-loving tradition. The small Mediterranean nation holds the second place (tied with Cyprus) among EU members with the highest share of cash transactions, while due to the country’s history, citizens are inclined to keep significant amounts or parts of their savings stored at home, something that helped soften the impact of the capital control measures.
Furthermore, there is another important risk as the war on cash escalates, affecting significant parts of the population, namely the threat of financial exclusion. In most Nordic countries, among the first and most eager to adopt the move from cash to electronic money, pensioners have seriously struggled with the shift, as they do not use the internet or have access to online banking. In Norway, the conversion to cashless bank branches has left many towns without a single bank, the Swedish National Pensioners Organization has stressed that 1 million people in the country are not ready for cashless transactions, while Denmark’s DaneAge Association, representing more than 750,000 senior citizens, has strongly criticized the limits on cash-based payments. Apart from the elderly, those at the lower end of socio-economic pyramid are also victimized by these policies. The war on cash effectively ensures that those without access to baking services, those living in poverty and the homeless population is banned from participating in the economy and by extension socially marginalized even more.
https://newsroom.proaurum.de/wp-cont..._2-600x361.jpg
Once again, let us underline the practical and realistic nature of this threat, by recalling another real-life example, this time from India. Following the Indian government’s decision in 2016 to withdraw the very widely used 500- and 1000-rupee notes from circulation, a policy that we know now has spectacularly failed in its objectives, the disastrous implementation of the law saw chaos reign all over the country and the economy in disarray. Business operations were disrupted, employees went unpaid and even everyday transactions, as simple as grocery shopping, became a formidable challenge. During this mayhem, tens of millions of Indians, having no access to banking services and most of them from the lowest economic strata, found themselves without the means to pay for their basic needs. As their money wasn’t accepted anymore, they were deprived of bare necessities, including food, essential medicine and medical services. The situation was so dire, that dozens of people died. This even included children and infants that were refused treatment in hospitals, as the staff would not accept their families’ banknotes as payment.
The way forward
Given the aggressive and persistent steps that governments, institutions and banks have taken so far to annihilate cash, it is reasonable to expect the pressure to keep building up. However, while the fate of physical banknotes might be already sealed, it definitely doesn’t mean that investors, savers and everyday citizens have no moves left.
The technological progress that has allowed this shift away from individual financial sovereignty to take place to begin with is now providing ways to reclaim it. The rise of cryptocurrencies and of decentralized systems that protect their users’ privacy and eliminate the need for a central authority have already shown great promise. And while their disruptive potential might indeed be considerable, their real strength arguably lies in the fact that they provide more choices to consumers, adding options, instead of limiting them and allowing free, voluntary engagement with different ideas and concepts, instead of forcing people to use a single system.
While new technologies might one day prove valuable tools to resist centralization and to keep transactions outside the banking system, when it comes to saving and storing value, the solution has always been there. As cash and the relative autonomy that came with it quickly fades, the role of precious metals becomes more important than ever. Physical gold and silver, stored outside the banking system and in a stable jurisdiction, such as Switzerland, is an essential step towards limiting one’s exposure to these risks, preserving wealth and safeguarding one’s autonomy and financial independence. Combined with the potential of new blockchain-based technologies and the capacity for the digitalization of real assets, gold can even be used in a decentralized trading platform, where it can be traded outside the banking system, offering the capacity to overcome controlling governmental pressures and reclaim privacy rights.
Claudio Grass, Hünenberg See, Switzerland
www.claudiograss.ch
- #6,644
- May 29, 2019 3:32am May 29, 2019 3:32am
- | Commercial User | Joined Dec 2014 | 14,164 Posts
https://www.armstrongeconomics.com/m...Ixxrg.facebook
Many people are confused as to why corporations have been buying back their shares in mass. The latest figures for 2018 are in and they demonstrate that the S&P 500 listed companies spent more on dividends and buybacks in 2018 than they actually made in total reported earnings ($1.26 trillion vs $1.1 trillion).
What is really fascinating is that of the 500 listed companies, 444 have bought back their own shares. Buybacks alone have actually come in at 66% of reported earnings over the last five years. Since 2014, buybacks and dividends combined have exceeded the total increase in S&P 500 market capitalization by $1.3 trillion. In other words, buybacks alone represent 87% of the increase in S&P 500 market capitalization during that period.
Buying back shares at this stage has been massive, but companies have been taking advantage of the cheap interest rates. When interest rates collapsed to artificially low levels, it became economically more efficient to buy back the shares at such a low cost, and this, in turn, will increase the dividend yields. This mix of low interest rates has had a reverse impact on equities. There is no question that companies are keenly aware of just how important their buyback programs are to their share prices.
As long as interest rates are cheap, then it’s hard to see them stopping unless the cost of borrowing forces them to do so. This is also setting the stage for a shortage in equities when capital begins to realize that there is a huge problem brewing on the public debt side of the balance sheet.
Categories: S&P 500
Tags: corporate buybacks, Interest Rates, S&P 500
« Private Blog: The Shift From Public to Private – US Share Market
Many people are confused as to why corporations have been buying back their shares in mass. The latest figures for 2018 are in and they demonstrate that the S&P 500 listed companies spent more on dividends and buybacks in 2018 than they actually made in total reported earnings ($1.26 trillion vs $1.1 trillion).
What is really fascinating is that of the 500 listed companies, 444 have bought back their own shares. Buybacks alone have actually come in at 66% of reported earnings over the last five years. Since 2014, buybacks and dividends combined have exceeded the total increase in S&P 500 market capitalization by $1.3 trillion. In other words, buybacks alone represent 87% of the increase in S&P 500 market capitalization during that period.
Buying back shares at this stage has been massive, but companies have been taking advantage of the cheap interest rates. When interest rates collapsed to artificially low levels, it became economically more efficient to buy back the shares at such a low cost, and this, in turn, will increase the dividend yields. This mix of low interest rates has had a reverse impact on equities. There is no question that companies are keenly aware of just how important their buyback programs are to their share prices.
As long as interest rates are cheap, then it’s hard to see them stopping unless the cost of borrowing forces them to do so. This is also setting the stage for a shortage in equities when capital begins to realize that there is a huge problem brewing on the public debt side of the balance sheet.
Categories: S&P 500
Tags: corporate buybacks, Interest Rates, S&P 500
« Private Blog: The Shift From Public to Private – US Share Market
- #6,646
- Jun 1, 2019 5:41pm Jun 1, 2019 5:41pm
- | Commercial User | Joined Dec 2014 | 14,164 Posts
http://classicalcapital.com/Learning...MCAl3cSwmZh_tU
Learning Curve of Fed
THE LEARNING CURVE OF THE FEDERAL RESERVE
U.S. Monetary Policy 1965-2005
By Wayne Jett
2005
October 6, 2004, marked the 25th anniversary of the Federal Reserve’s move from an interest rate target to a money growth target as the tool chosen for fighting inflation. The Federal Reserve Bank of St. Louis convened a conference to consider how current U.S. monetary policy is informed by that 1979 milestone, by open market operations with money growth targets, and by 22 years of experience since the Fed abandoned money growth targets in 1982.
Three major papers were presented, plus commentaries on each, and two panels discussed their merits. Were monetary issues not such a crucial weakness in U.S. public policy, and thus a significant global concern, the St. Louis discussions might slide by as an academic exercise.
But they deserve attention. Not because they are clairvoyant or comprehensive – they are neither. In fact, the St. Louis discussions were often politically correct in the academic sense. The commentators were demand-side economists evaluating demand-side policies implemented by the Federal Reserve. Some sins are overstated, some go unnoticed and some are forgiven too quickly.
“Origins of the Great Inflation”
On the other hand, many insights are available, both in what is said and in what is not. Allan H. Meltzer of Carnegie Mellon University marks the “Great Inflation” as running from 1965 to 1984, emphasizes Fed conduct in 1965, and concludes that Fed chairman William McChesney Martin “… was in a position to stop…” inflation until January, 1970, but “… failed to do so.”
Meltzer reports that inflation “destroyed” the Bretton Woods protocol for the international monetary system, so the Fed and all other central banks were forced to stabilize their currencies with their own policies and ideas. He concludes that the Fed’s economic theories, despite flaws, were sufficient to defeat inflation, but politics (particularly unwillingness to pay the trade-off of higher unemployment) prevented effective action.
Christina D. Romer of UC Berkeley sees the cause of the Great Inflation somewhat differently. Defective theory involving the “natural rate” of unemployment required to prevent inflation came into use in the mid-1960s giving rise to moderate inflation. Both theory and inflation worsened in the early 1970s, and then improved before turning worse yet into the late ‘70s. During this time, Fed chairman Arthur Burns saw the Fed’s primary role as “managing aggregate demand” to achieve “a return to price stability.” Nevertheless, after “tightening” during recession in 1974, Burns “led rapid monetary expansion in 1977.”
In Romer’s view, ideas began the Great Inflation and ideas ended it. So politics were not entirely to blame, although unwillingness to pay the “natural” unemployment price for low inflation played a role. Romer refines an improved idea from this experience: “inflation can be controlled by aggregate demand policy,” which she credits as the idea that “fueled the Volcker disinflation” and “broke the back of inflation worldwide.”
“The Reform of 1979 – How and Why It Happened”
Other commentators at the St. Louis conference from the Federal Reserve System (Lindsey, Orphanides and Rasche) point out that the Paul Volcker-led Fed on October 6, 1979, conditionally adopted a target for aggregate money growth, not aggregate demand. Volcker led the move to money growth targets from interest rate targets, not as a monetarist, but partly to shield the Fed from public criticism for sharp rises in interest rates.
These commentators note that, while targeting money quantities in 1980, Volcker lamented the murkiness of any relationship between money quantities and GDP growth, and the arbitrariness of defining and measuring money. The Fed abandoned money aggregate targets in mid-1982, and money aggregates play no role in today’s Fed operations.
Monetary Policy Debate Since 1979
Marvin Goodfriend of the Richmond Fed describes the “consensus model” of monetary theory. Depending on who is using it, the model is sometimes called the New Neoclassical Synthesis Model and other times the New Keynesian Model. The model focuses on managing aggregate demand to optimize unemployment at its “natural rate” where “output equals potential.”
Goodfriend perceives an irony that “monetarists deserve much of the credit” for defeating virulent inflation in the early 1980s, “yet the Fed currently ignores money” quantities. He argues that money quantities ought to be integrated into Fed operations “to some extent.” He further notes that U.S. monetary policy has had no anchor for the dollar since the Bretton Woods international monetary protocol “collapsed in 1973.”
Goodfriend observes that neither Congress nor the Fed has acted to provide a dollar anchor, and concedes that recent developments may make an anchor unnecessary. But he contends the desirability of an anchor “is [at least] debatable” in view of changing Fed membership and U.S. fiscal policy. Nonetheless, Goodfriend sees monetary theory and policy as “revolutionized in the two decades since the Federal Reserve moved in October 1979 to stabilize inflation and bring it down.”
If the views related so far indicate a significant degree of divergence from consensus within demand-side monetary theory, stay tuned. Laurence M. Ball of The Johns Hopkins University reviews Goodfriend’s survey of “current mainstream thought,” asserts no revolution has occurred since 1979, and credits Milton Friedman’s 1968 “precise theory of the Phillips curve” as “still the best simple theory of the unemployment-inflation trade-off.”
Ball questions the usefulness of “rational expectations theory” (nee “credibility” of central banks) for “understanding inflation in the real world” and he finds “little evidence that inflation targeting changes the behavior of output or inflation.” Moreover, Ball examines the “modern consensus model,” describes it as “wildly counterfactual,” and concludes its “absurd predictions make it a poor tool for policy analysis.” He shows that corrections necessary to make the “modern consensus model” useful amount to abandoning it and returning to Friedman’s 1968 re-statement of the Phillips curve theory.
Ball reports that “the Fed has not been unusually successful in reducing inflation” and has, in fact, been “near the middle of the pack” among the world’s central banks. He says reducing inflation is “easy to accomplish … if policy-makers are willing to slow the economy sufficiently.”
Ball credits U.S. unemployment performance as excelling compared to other countries, but dissents “180 degrees” from Goodfriend’s view that the reason is the Fed’s unflinching inflation fight. Ball says U.S. unemployment has been relatively low because the Fed “has not been as single-minded about fighting inflation” as other central banks.
Anna J. Schwartz of the National Bureau of Economic Research, speaking on behalf of monetarists at the St. Louis conference, says the economics profession now embraces the belief that “… there is no long-run trade-off between inflation and unemployment….”
With dissension of this magnitude within its ranks, is criticism from outside the demand-side fraternity really necessary? Of course. With disagreement of such fundamental gravity among those who guide U.S. monetary policy, inquiry into the soundness of the Fed’s theory and practices is urgently needed.
A Classical Critique of Demand-Side Theory
The question above may not seem serious, but the answer requires understanding that demand-side economics and classical (supply-side) economics are not merely two divergent branches of a common intellectual field of inquiry. Demand-side theory is relatively recent in origin, first gaining traction through Depression-era politics of the Franklin Roosevelt presidency.
Young advisors surrounding FDR undertook development of intellectual theories to support federal relief programs. These theorists tended to examine the economy from the viewpoint of the central planner, and from the viewpoints of political constituencies, primarily consumers. The resulting economic ideas were often attributed to the English classical economist, John Maynard Keynes, although he did not participate actively in their development and is known to have dissented from them at times in occasional written comments to FDR.
Given primacy as foundation for federal government programs during five consecutive presidential terms (1932-1952), demand-side economic theory gained firm footholds both in public policy and in academia. By the mid-20th century, demand-side theory was well established in academic institutions alongside classical economics. In the ensuing 50 years, demand-side theory came to dominate the academy so thoroughly (to the exclusion of classical economics) that no institution of higher learning presently offers an accredited degree in classical economics.
Classical economics came through Adam Smith, Alexander Hamilton and others who probed conditions that promote individual productivity and prosperity. Classical theory fashioned public policy accordingly. The gestation of classical theory was much longer than demand-side, though the “supply-side” descriptive name for classical economics is more recent.
Classical theory was dubbed “supply-side economics” in the midst of the Great Inflation of the 1970s, partly because classical economics had been wrongly faulted as blameworthy in the Crash of 1929 and the Great Depression. The case showing serious violations of classical theory as the true culprits, thus exonerating classicists, has been made elsewhere to willing minds. The focus here will remain the merits of current U.S. monetary theory and policy.
The point of this passing reference to the genesis of demand-side theory is that it was born of a political motive to escape classical principles. From the outset, monetary and fiscal principles of classical economic theory were politically troublesome to New Deal policy-makers.
While the U.S. remained ostensibly on the gold standard, FDR devalued the dollar from $20.67 to $35 per ounce of gold in 1934. The dollar devaluation introduced 41 percent inflation into the U.S. economy as the cheaper dollar worked its way through private transactions in ensuing years.
In addition, FDR confiscated privately owned gold, paying the pre-devaluation price of $20.67 with post-devaluation dollars. Combined as it was with dollar devaluation, the gold confiscation amounted to federal seizure of a major portion of private investment capital in the nation.
This federal confiscation of private capital debilitated investment in production and employment, importantly setting back economic recovery. Making matters far worse, legislative “reform” of the Federal Reserve in 1935 gave FDR effective control of the Fed. The FDR-dominated Fed further contracted the private economy by twice radically increasing required bank reserves in 1936-37 after the banks had already safely rebuilt reserves, assuring that banks could make no new loans and would have to call in existing loans.
Another aspect of Roosevelt’s influence deserves acknowledgment in the current debate of U.S. monetary policy. FDR viewed the analyses developed by his aides and called “Keynesian,” not as serious economic theory, but as intellectual cover for his political programs.
The diaries of FDR’s Treasury secretary, Henry Morgenthau, record their discussions of March 5 and 7, 1939, when FDR suggested to Morgenthau greater government spending to off-set the business downturn. Morgenthau countered FDR by proposing tax cuts he assured would produce “… within a month … a boom.”
Roosevelt admonished Morgenthau for bringing him “a Mellon plan of taxation” that would signal a victory by his political foes in business, ridiculed as “very stupid” a small sign (“Does It Contribute to Recovery?”) Morgenthau kept on his desk, instructed “this is a matter of politics,” and shouted as Morgenthau and his undersecretary John W. Hanes departed his office “For God’s sake, don’t be so innocent!”
Innocent or not, academia continues to treat demand-side theory as serious intellectual endeavor, much to the detriment of scholarship and global economic progress. The Federal Reserve Board and staff follow in its thrall. Regardless of guile, no chain of abstractions can achieve price stability while the currency unit value fluctuates unpredictably.
The Bretton Woods Responsibility
Under the Bretton Woods protocol of 1944, the U.S. took upon itself the key role in the international monetary system. The U.S. was obliged to maintain the dollar’s value at $35 per gold ounce, so that every other currency could link its own value to the dollar.
The Bretton Woods protocol did not simply collapse of its own accord, nor fail because it was unworkable, nor was it innocently “destroyed by inflation.” The Bretton Woods protocol was destroyed by the failure of the U.S. Federal Reserve to honor its obligation to maintain the dollar’s value. The Fed knowingly created inflation by issuing excess currency to fund federal debt at below-market interest rates.
The Fed’s practice of accommodating federal debt appeared subtly in the 1950s, reappeared in the mid-60s, and grew each year as demand-side theory became more supportive. The seminal event, going entirely unremarked at the St. Louis conference of 2004, occurred August 15, 1971, when President Nixon closed the gold window to European central banks. By mid-1972, the price of gold doubled and, by Spring 1975 hit $200 per ounce, five times the price four years earlier. (Figure 1)
Why would the noted scholars of St. Louis 2004 avoid mentioning such an obviously pivotal event that unleashed soaring inflation on U.S. and world economies during the following years? The answer is patently obvious. Acknowledgment of the importance of cutting the dollar’s anchor to gold would raise questions whether that was the central error, and whether it should be reversed.
Gold Bullion Price-New York (US$/Ounce) (Symbol: __XAU_D)
http://classicalcapital.com/images/g..._1986_ktxu.bmp
Figure 1.
Sadly, to sidestep the same subject, the esteemed outgoing chairman of the Fed, Alan Greenspan, testified to Congress on July 21, 2005, that no advantage exists in returning U.S. monetary policy to the gold standard. Why? “Because we’re acting as though we were there.” From an eminently educated economist who witnessed the gold price move unpredictably between $250 and $480 per ounce during his last ten years in office, this testimony is difficult to fathom.
http://classicalcapital.com/images/ten_year_gold.bmp
Figure 2.
Admirers of Chaos
When the gold standard rule was lifted in 1971, discretionary power was conferred upon the Fed chairman that no incumbent has been willing to yield. This power includes use of currency creation to resolve crises encountered - a discretion quite attractive to private banks wishing assistance on occasion. Another faction loving the status quo floating dollar is the foreign exchange investment community, which presently invests more funds in currencies than are invested in corporate stocks and bonds.
The Fed could choose, as chairman Greenspan says it has, to behave as if it is on the gold standard. The Fed could adopt a price target for gold and create only the number of dollars required to hit the target. The benefits of a stable dollar to the U.S. economy, to other G8 economies and to emerging economies would be very significant. Of course, a stable dollar would be much less interesting to forex speculators.
This may not be as apparent to those guiding the Fed as it should be. Demand-side theory is deeply embedded in the thought processes of Fed policy-makers. Economic theory can misguide attention, confuse thinking and produce counter-productive actions despite good intentions.
New Reality Show: 1979-1982
The October 6, 1979, Fed meeting provides a case in point. Commentators in St. Louis 25 years later unanimously credited that meeting as a turning point in the fight against inflation. No one acknowledged that inflation skyrocketed after the meeting and as a result of the actions taken.
In adopting a new target for money growth, the Fed misjudged the appropriate limits on money quantities and actually added substantial new liquidity to the economy. In response, the price of gold (which had been $240 in the Spring and below $300 in August of 1979) spiked to $890 per ounce in February, 1980. During 1980, the gold price fell to $500, and then rose again to $750 before ending the year above $600. (Figure 3.)
After the 1980 election of President Reagan raised prospects of significant cuts in marginal tax rates, demand for dollars increased and the dollar’s value recovered sharply. With economic growth absorbing excess monetary liquidity, the gold price ended 1981 near $400.
The gold price fall (dollar appreciation) continued in early 1982, slipping $10 on St. Patrick’s Day to $310, and commodity prices adjusted to the deflated dollar as they must. Classical economists Robert A. Mundell of Columbia University and Jude Wanniski alerted Fed chairman Volcker that dollar deflation below $300 gold would cause severe distress in financial institutions and commodity-based industries. Regardless, the Fed remained attentive to the views of monetarists who insisted addition of liquidity would re-ignite inflation and collapse the bond market.
In August, 1982, Mexico notified U.S. banks of its impending default on loans collateralized by oil, since the oil price had fallen $5 below the “tipping point” of $36 needed to repay the loans. The Fed had no choice but to abandon monetarist advice and monetize $3 billion in Mexican bonds to avoid the default endangering U.S. banks.
Gold Bullion Price-New York (US$/Ounce) (Symbol: __XAU_D)
http://classicalcapital.com/images/g..._1979_1987.bmp
Figure 3.
On this news, the gold price moved higher, but interest rates did not follow. Instead, the bond market rallied strongly and equity markets surged (DJIA from 790 to 1100 and NASDAQ from 150 to 250 at year-end). Economic growth had strengthened the dollar but required a stable dollar (meaning sufficient liquidity) in order to continue at rates permitted by the cuts in marginal tax rates.
One will not find these facts and analysis examined, much less expressed as consensus, in the St. Louis proceedings. Demand-side commentators acknowledge that the Fed abandoned money quantity targets in 1982, but are far too lenient in explaining why monetarism theory failed in practice.
Selection of the appropriate measure of money, current gauging of money growth, estimate of liquidity requirements – each of these proved to be beyond the capability of Fed planners in 1979. Moreover, the crucial “velocity” factor assumed by monetarist theory to be very stable (as Friedman concluded it had been during the gold standard) turned out otherwise. In short, the monetarism experiment begun by the Fed October 6, 1979, failed miserably and was near disaster from beginning to end.
Today’s Demand-Side: A Bankrupt Central Tenet
On June 6, 2003, the Financial Times of London reported Milton Friedman’s concession that his theory of money quantities had failed. The St. Louis commentators made no such concession, and continue to honor as a central tenet of their economic model Friedman’s theory describing inflation as a trade-off for employment.
Another central tenet of demand-side theory credited to Professor Friedman is “… inflation is always and everywhere a monetary phenomenon.” Of the two tenets contributed by Friedman, demand-side theorists should recognize, but apparently do not, that they must choose which to believe is valid. Both cannot be true.
Classical economists have no difficulty making the choice. A monetary phenomenon is one exhibited by the currency managed by the central bank. Inflation is always and everywhere a monetary phenomenon, and thus is a creature that lives and dies by the hand of the central banker.
This being the case, then who could believe that inflation is caused when the employment level rises above a “natural” rate? Apparently the demand-siders who guide the Fed believe it. So they choose as the Fed’s only inflation-fighting “tool” an interest rate target that provides no prospect of stabilizing the dollar’s value. The Fed actually wields the funds rate target as an instrument of fiscal policy to raise and lower the government-imposed cost of doing business, much as tax laws do.
As reflected in the St. Louis proceedings, the Fed uses the funds rate target to manage “aggregate demand.” By raising the funds rate target to reduce aggregate demand, the Fed aims to slow production, thereby increasing unemployment so wage-push inflationary pressures will be subdued.
Often Fed actions run directly contrary to congressional or executive branch fiscal policy. Demand-siders view this as a benefit of the “independent” Fed, so that expert economic planners are empowered to offset fiscal “excesses” of the elected branches of government.
Let’s be clear about why inflation is a monetary phenomenon and why inflation is not caused by employment. Inflation (or deflation) is a change in value of the monetary unit. Any such deterioration in monetary unit value must be worked through the entire pricing system of the economy to preserve the value of property, goods and services. The Fed can control the unit value of its currency; workers cannot control or affect the unit value of currency received as pay.
By treating the employment level as a purveyor of inflation, the Fed robs the labor market of the benefits of supply and demand signals. Oil, e.g., needs a trustworthy signal of a higher oil price to justify investment in more production. When labor is in short supply, the signal of higher wages will attract more workers. Meanwhile, workers who can provide the desired services during the shortage are entitled to gain from their market advantage. This does nothing to produce inflation. If workers are not permitted to gain in periods of labor shortage, the market will not work to supplement and replenish supply.
By slowing economic growth to produce higher unemployment, the Fed reduces demand for dollars in the productive economy without removing dollars from the system. This results in greater excess liquidity and more inflation. The Fed could hardly design a more counter-productive way of conducting itself.
As it produces inflation through creation of excess liquidity, the Fed impedes the validity of market price signals. Untrustworthy currency undercuts the supply message given by higher wages or prices. Labor is handicapped by bad money in this manner, as are all other goods and services. But labor is dealt a doubly damaging blow by the Fed’s erroneous embrace of Phillips curve theory, even as refined by Friedman. The Fed beats down any employment rate above what is perceived as “natural” by Phillips curve theorists.
Thus, the U.S. market for human services is furnished a deteriorating currency by the Fed. The Fed then acts to prevent the workers from adjusting to the changed currency value. Workers might choose to work more, or require more members of the household to work, to restore purchasing power. Regardless, the Fed acts with its funds rate target “tool” to slow economic growth and reduce employment opportunities.
This is unwise management of the most important central bank in the world, and a great disservice to all workers. The labor markets of the world cannot function fairly or efficiently under such irrational handicaps imposed by central planning.
When the unit value of the dollar is changing, the Fed cannot achieve price stability by managing the output gap by managing aggregate demand by managing the funds rate target. This chain of abstractions strung together by demand-side theorists to guide Fed practices ignores reality, without escaping it. When the dollar changes value, prices measured in dollars must be adjusted to maintain accurate, fair value in transactions.
The market supply/demand mechanism works best when the currency unit value does not change. To achieve currency value stability, the central bank must target the desired value and act directly to achieve it. Here, theoretical simplicity is to be admired, and will be rewarded with greater prosperity around the world.
The roundabout demand-side theory now dominant at the Fed and other central banks will not work. Flaws in use of the funds rate target itself are only part of the problem, but are significant. Here are the most significant flaws:
• The funds rate is not a controlling variable in the dollar’s value, so changing the funds rate produces no predictable change in the dollar’s value.
• Under Fed practices, raising the funds rate target does not actually “tighten” flow or quantity of dollar liquidity; it merely raises the cost of capital.
• The Fed cannot really control the funds rate target, since market pressures force the Fed to change the target against its wishes.
• The Fed’s attempts to control the funds rate cause market conditions to change in ways they would not otherwise, thereby destabilizing the dollar’s unit value.
The monetarist Anna Schwartz reported at St. Louis a consensus that “… there is no long-run trade-off between unemployment and inflation….” Indeed, demand-side economists do use this statement uniformly. Yet Goodfriend and Ball showcase the existing consensus supporting Friedman’s definition of the Phillips curve trade-off between unemployment and inflation.
Thus, denial of any long-run link between unemployment and inflation merely serves to mask the Fed’s practice of targeting a higher funds rate to reduce aggregate demand, slow economic growth and raise unemployment in the short-run to reduce inflation. One presently out of work would remind demand-siders, as Keynes did long ago, that “in the long-run we are all dead.”
Demand-side monetary theory is bankrupt, having no essentially valid core. The Phillips curve inflation-unemployment “trade-off” is theoretically absurd, and its effects are diabolical on workers at every income level. The Fed’s manipulation of the funds rate target destabilizes other market variables affecting the dollar’s value, so isolation of employment as inflation’s controlling variable is both logically indefensible and morally repugnant.
There being no true inflation-unemployment trade-off, the entire demand-side theory chain that aims to slow the economy is misconceived. There is no point to slowing the economy, since no theoretically sound reason exists to raise unemployment.
Though debate of monetary policy may seem esoteric to some, misery flowing from the errors discussed has many human faces. Service as the reserve currency of the world carries with it grave moral responsibilities. The standard of living of many societies – American, Mexican, Brazilian, Argentine, Korean, Thai, Chinese, Russian, African - has suffered greatly from the U.S. Federal Reserve’s failure to meet its duty to provide honest currency. The Fed’s use of complex oratory does not hide the inadequacy of its policy, nor does it meet America’s moral obligation to act uprightly as a nation.
The Fed’s management of the dollar has fallen short of American standards. Demand-side theory ought to be cast out of the Fed’s operations immediately, freeing central banks worldwide to follow sound monetary principles. What ought to replace it is a simple rule targeting the desired value of the dollar relative to gold. If the Fed will not do so, the President or the Congress should provide leadership. ~
Learning Curve of Fed
THE LEARNING CURVE OF THE FEDERAL RESERVE
U.S. Monetary Policy 1965-2005
By Wayne Jett
October 6, 2004, marked the 25th anniversary of the Federal Reserve’s move from an interest rate target to a money growth target as the tool chosen for fighting inflation. The Federal Reserve Bank of St. Louis convened a conference to consider how current U.S. monetary policy is informed by that 1979 milestone, by open market operations with money growth targets, and by 22 years of experience since the Fed abandoned money growth targets in 1982.
Three major papers were presented, plus commentaries on each, and two panels discussed their merits. Were monetary issues not such a crucial weakness in U.S. public policy, and thus a significant global concern, the St. Louis discussions might slide by as an academic exercise.
But they deserve attention. Not because they are clairvoyant or comprehensive – they are neither. In fact, the St. Louis discussions were often politically correct in the academic sense. The commentators were demand-side economists evaluating demand-side policies implemented by the Federal Reserve. Some sins are overstated, some go unnoticed and some are forgiven too quickly.
“Origins of the Great Inflation”
On the other hand, many insights are available, both in what is said and in what is not. Allan H. Meltzer of Carnegie Mellon University marks the “Great Inflation” as running from 1965 to 1984, emphasizes Fed conduct in 1965, and concludes that Fed chairman William McChesney Martin “… was in a position to stop…” inflation until January, 1970, but “… failed to do so.”
Meltzer reports that inflation “destroyed” the Bretton Woods protocol for the international monetary system, so the Fed and all other central banks were forced to stabilize their currencies with their own policies and ideas. He concludes that the Fed’s economic theories, despite flaws, were sufficient to defeat inflation, but politics (particularly unwillingness to pay the trade-off of higher unemployment) prevented effective action.
Christina D. Romer of UC Berkeley sees the cause of the Great Inflation somewhat differently. Defective theory involving the “natural rate” of unemployment required to prevent inflation came into use in the mid-1960s giving rise to moderate inflation. Both theory and inflation worsened in the early 1970s, and then improved before turning worse yet into the late ‘70s. During this time, Fed chairman Arthur Burns saw the Fed’s primary role as “managing aggregate demand” to achieve “a return to price stability.” Nevertheless, after “tightening” during recession in 1974, Burns “led rapid monetary expansion in 1977.”
In Romer’s view, ideas began the Great Inflation and ideas ended it. So politics were not entirely to blame, although unwillingness to pay the “natural” unemployment price for low inflation played a role. Romer refines an improved idea from this experience: “inflation can be controlled by aggregate demand policy,” which she credits as the idea that “fueled the Volcker disinflation” and “broke the back of inflation worldwide.”
“The Reform of 1979 – How and Why It Happened”
Other commentators at the St. Louis conference from the Federal Reserve System (Lindsey, Orphanides and Rasche) point out that the Paul Volcker-led Fed on October 6, 1979, conditionally adopted a target for aggregate money growth, not aggregate demand. Volcker led the move to money growth targets from interest rate targets, not as a monetarist, but partly to shield the Fed from public criticism for sharp rises in interest rates.
These commentators note that, while targeting money quantities in 1980, Volcker lamented the murkiness of any relationship between money quantities and GDP growth, and the arbitrariness of defining and measuring money. The Fed abandoned money aggregate targets in mid-1982, and money aggregates play no role in today’s Fed operations.
Monetary Policy Debate Since 1979
Marvin Goodfriend of the Richmond Fed describes the “consensus model” of monetary theory. Depending on who is using it, the model is sometimes called the New Neoclassical Synthesis Model and other times the New Keynesian Model. The model focuses on managing aggregate demand to optimize unemployment at its “natural rate” where “output equals potential.”
Goodfriend perceives an irony that “monetarists deserve much of the credit” for defeating virulent inflation in the early 1980s, “yet the Fed currently ignores money” quantities. He argues that money quantities ought to be integrated into Fed operations “to some extent.” He further notes that U.S. monetary policy has had no anchor for the dollar since the Bretton Woods international monetary protocol “collapsed in 1973.”
Goodfriend observes that neither Congress nor the Fed has acted to provide a dollar anchor, and concedes that recent developments may make an anchor unnecessary. But he contends the desirability of an anchor “is [at least] debatable” in view of changing Fed membership and U.S. fiscal policy. Nonetheless, Goodfriend sees monetary theory and policy as “revolutionized in the two decades since the Federal Reserve moved in October 1979 to stabilize inflation and bring it down.”
If the views related so far indicate a significant degree of divergence from consensus within demand-side monetary theory, stay tuned. Laurence M. Ball of The Johns Hopkins University reviews Goodfriend’s survey of “current mainstream thought,” asserts no revolution has occurred since 1979, and credits Milton Friedman’s 1968 “precise theory of the Phillips curve” as “still the best simple theory of the unemployment-inflation trade-off.”
Ball questions the usefulness of “rational expectations theory” (nee “credibility” of central banks) for “understanding inflation in the real world” and he finds “little evidence that inflation targeting changes the behavior of output or inflation.” Moreover, Ball examines the “modern consensus model,” describes it as “wildly counterfactual,” and concludes its “absurd predictions make it a poor tool for policy analysis.” He shows that corrections necessary to make the “modern consensus model” useful amount to abandoning it and returning to Friedman’s 1968 re-statement of the Phillips curve theory.
Ball reports that “the Fed has not been unusually successful in reducing inflation” and has, in fact, been “near the middle of the pack” among the world’s central banks. He says reducing inflation is “easy to accomplish … if policy-makers are willing to slow the economy sufficiently.”
Ball credits U.S. unemployment performance as excelling compared to other countries, but dissents “180 degrees” from Goodfriend’s view that the reason is the Fed’s unflinching inflation fight. Ball says U.S. unemployment has been relatively low because the Fed “has not been as single-minded about fighting inflation” as other central banks.
Anna J. Schwartz of the National Bureau of Economic Research, speaking on behalf of monetarists at the St. Louis conference, says the economics profession now embraces the belief that “… there is no long-run trade-off between inflation and unemployment….”
With dissension of this magnitude within its ranks, is criticism from outside the demand-side fraternity really necessary? Of course. With disagreement of such fundamental gravity among those who guide U.S. monetary policy, inquiry into the soundness of the Fed’s theory and practices is urgently needed.
A Classical Critique of Demand-Side Theory
The question above may not seem serious, but the answer requires understanding that demand-side economics and classical (supply-side) economics are not merely two divergent branches of a common intellectual field of inquiry. Demand-side theory is relatively recent in origin, first gaining traction through Depression-era politics of the Franklin Roosevelt presidency.
Young advisors surrounding FDR undertook development of intellectual theories to support federal relief programs. These theorists tended to examine the economy from the viewpoint of the central planner, and from the viewpoints of political constituencies, primarily consumers. The resulting economic ideas were often attributed to the English classical economist, John Maynard Keynes, although he did not participate actively in their development and is known to have dissented from them at times in occasional written comments to FDR.
Given primacy as foundation for federal government programs during five consecutive presidential terms (1932-1952), demand-side economic theory gained firm footholds both in public policy and in academia. By the mid-20th century, demand-side theory was well established in academic institutions alongside classical economics. In the ensuing 50 years, demand-side theory came to dominate the academy so thoroughly (to the exclusion of classical economics) that no institution of higher learning presently offers an accredited degree in classical economics.
Classical economics came through Adam Smith, Alexander Hamilton and others who probed conditions that promote individual productivity and prosperity. Classical theory fashioned public policy accordingly. The gestation of classical theory was much longer than demand-side, though the “supply-side” descriptive name for classical economics is more recent.
Classical theory was dubbed “supply-side economics” in the midst of the Great Inflation of the 1970s, partly because classical economics had been wrongly faulted as blameworthy in the Crash of 1929 and the Great Depression. The case showing serious violations of classical theory as the true culprits, thus exonerating classicists, has been made elsewhere to willing minds. The focus here will remain the merits of current U.S. monetary theory and policy.
The point of this passing reference to the genesis of demand-side theory is that it was born of a political motive to escape classical principles. From the outset, monetary and fiscal principles of classical economic theory were politically troublesome to New Deal policy-makers.
While the U.S. remained ostensibly on the gold standard, FDR devalued the dollar from $20.67 to $35 per ounce of gold in 1934. The dollar devaluation introduced 41 percent inflation into the U.S. economy as the cheaper dollar worked its way through private transactions in ensuing years.
In addition, FDR confiscated privately owned gold, paying the pre-devaluation price of $20.67 with post-devaluation dollars. Combined as it was with dollar devaluation, the gold confiscation amounted to federal seizure of a major portion of private investment capital in the nation.
This federal confiscation of private capital debilitated investment in production and employment, importantly setting back economic recovery. Making matters far worse, legislative “reform” of the Federal Reserve in 1935 gave FDR effective control of the Fed. The FDR-dominated Fed further contracted the private economy by twice radically increasing required bank reserves in 1936-37 after the banks had already safely rebuilt reserves, assuring that banks could make no new loans and would have to call in existing loans.
Another aspect of Roosevelt’s influence deserves acknowledgment in the current debate of U.S. monetary policy. FDR viewed the analyses developed by his aides and called “Keynesian,” not as serious economic theory, but as intellectual cover for his political programs.
The diaries of FDR’s Treasury secretary, Henry Morgenthau, record their discussions of March 5 and 7, 1939, when FDR suggested to Morgenthau greater government spending to off-set the business downturn. Morgenthau countered FDR by proposing tax cuts he assured would produce “… within a month … a boom.”
Roosevelt admonished Morgenthau for bringing him “a Mellon plan of taxation” that would signal a victory by his political foes in business, ridiculed as “very stupid” a small sign (“Does It Contribute to Recovery?”) Morgenthau kept on his desk, instructed “this is a matter of politics,” and shouted as Morgenthau and his undersecretary John W. Hanes departed his office “For God’s sake, don’t be so innocent!”
Innocent or not, academia continues to treat demand-side theory as serious intellectual endeavor, much to the detriment of scholarship and global economic progress. The Federal Reserve Board and staff follow in its thrall. Regardless of guile, no chain of abstractions can achieve price stability while the currency unit value fluctuates unpredictably.
The Bretton Woods Responsibility
Under the Bretton Woods protocol of 1944, the U.S. took upon itself the key role in the international monetary system. The U.S. was obliged to maintain the dollar’s value at $35 per gold ounce, so that every other currency could link its own value to the dollar.
The Bretton Woods protocol did not simply collapse of its own accord, nor fail because it was unworkable, nor was it innocently “destroyed by inflation.” The Bretton Woods protocol was destroyed by the failure of the U.S. Federal Reserve to honor its obligation to maintain the dollar’s value. The Fed knowingly created inflation by issuing excess currency to fund federal debt at below-market interest rates.
The Fed’s practice of accommodating federal debt appeared subtly in the 1950s, reappeared in the mid-60s, and grew each year as demand-side theory became more supportive. The seminal event, going entirely unremarked at the St. Louis conference of 2004, occurred August 15, 1971, when President Nixon closed the gold window to European central banks. By mid-1972, the price of gold doubled and, by Spring 1975 hit $200 per ounce, five times the price four years earlier. (Figure 1)
Why would the noted scholars of St. Louis 2004 avoid mentioning such an obviously pivotal event that unleashed soaring inflation on U.S. and world economies during the following years? The answer is patently obvious. Acknowledgment of the importance of cutting the dollar’s anchor to gold would raise questions whether that was the central error, and whether it should be reversed.
Gold Bullion Price-New York (US$/Ounce) (Symbol: __XAU_D)
http://classicalcapital.com/images/g..._1986_ktxu.bmp
Figure 1.
Sadly, to sidestep the same subject, the esteemed outgoing chairman of the Fed, Alan Greenspan, testified to Congress on July 21, 2005, that no advantage exists in returning U.S. monetary policy to the gold standard. Why? “Because we’re acting as though we were there.” From an eminently educated economist who witnessed the gold price move unpredictably between $250 and $480 per ounce during his last ten years in office, this testimony is difficult to fathom.
http://classicalcapital.com/images/ten_year_gold.bmp
Figure 2.
Admirers of Chaos
When the gold standard rule was lifted in 1971, discretionary power was conferred upon the Fed chairman that no incumbent has been willing to yield. This power includes use of currency creation to resolve crises encountered - a discretion quite attractive to private banks wishing assistance on occasion. Another faction loving the status quo floating dollar is the foreign exchange investment community, which presently invests more funds in currencies than are invested in corporate stocks and bonds.
The Fed could choose, as chairman Greenspan says it has, to behave as if it is on the gold standard. The Fed could adopt a price target for gold and create only the number of dollars required to hit the target. The benefits of a stable dollar to the U.S. economy, to other G8 economies and to emerging economies would be very significant. Of course, a stable dollar would be much less interesting to forex speculators.
This may not be as apparent to those guiding the Fed as it should be. Demand-side theory is deeply embedded in the thought processes of Fed policy-makers. Economic theory can misguide attention, confuse thinking and produce counter-productive actions despite good intentions.
New Reality Show: 1979-1982
The October 6, 1979, Fed meeting provides a case in point. Commentators in St. Louis 25 years later unanimously credited that meeting as a turning point in the fight against inflation. No one acknowledged that inflation skyrocketed after the meeting and as a result of the actions taken.
In adopting a new target for money growth, the Fed misjudged the appropriate limits on money quantities and actually added substantial new liquidity to the economy. In response, the price of gold (which had been $240 in the Spring and below $300 in August of 1979) spiked to $890 per ounce in February, 1980. During 1980, the gold price fell to $500, and then rose again to $750 before ending the year above $600. (Figure 3.)
After the 1980 election of President Reagan raised prospects of significant cuts in marginal tax rates, demand for dollars increased and the dollar’s value recovered sharply. With economic growth absorbing excess monetary liquidity, the gold price ended 1981 near $400.
The gold price fall (dollar appreciation) continued in early 1982, slipping $10 on St. Patrick’s Day to $310, and commodity prices adjusted to the deflated dollar as they must. Classical economists Robert A. Mundell of Columbia University and Jude Wanniski alerted Fed chairman Volcker that dollar deflation below $300 gold would cause severe distress in financial institutions and commodity-based industries. Regardless, the Fed remained attentive to the views of monetarists who insisted addition of liquidity would re-ignite inflation and collapse the bond market.
In August, 1982, Mexico notified U.S. banks of its impending default on loans collateralized by oil, since the oil price had fallen $5 below the “tipping point” of $36 needed to repay the loans. The Fed had no choice but to abandon monetarist advice and monetize $3 billion in Mexican bonds to avoid the default endangering U.S. banks.
Gold Bullion Price-New York (US$/Ounce) (Symbol: __XAU_D)
http://classicalcapital.com/images/g..._1979_1987.bmp
Figure 3.
On this news, the gold price moved higher, but interest rates did not follow. Instead, the bond market rallied strongly and equity markets surged (DJIA from 790 to 1100 and NASDAQ from 150 to 250 at year-end). Economic growth had strengthened the dollar but required a stable dollar (meaning sufficient liquidity) in order to continue at rates permitted by the cuts in marginal tax rates.
One will not find these facts and analysis examined, much less expressed as consensus, in the St. Louis proceedings. Demand-side commentators acknowledge that the Fed abandoned money quantity targets in 1982, but are far too lenient in explaining why monetarism theory failed in practice.
Selection of the appropriate measure of money, current gauging of money growth, estimate of liquidity requirements – each of these proved to be beyond the capability of Fed planners in 1979. Moreover, the crucial “velocity” factor assumed by monetarist theory to be very stable (as Friedman concluded it had been during the gold standard) turned out otherwise. In short, the monetarism experiment begun by the Fed October 6, 1979, failed miserably and was near disaster from beginning to end.
Today’s Demand-Side: A Bankrupt Central Tenet
On June 6, 2003, the Financial Times of London reported Milton Friedman’s concession that his theory of money quantities had failed. The St. Louis commentators made no such concession, and continue to honor as a central tenet of their economic model Friedman’s theory describing inflation as a trade-off for employment.
Another central tenet of demand-side theory credited to Professor Friedman is “… inflation is always and everywhere a monetary phenomenon.” Of the two tenets contributed by Friedman, demand-side theorists should recognize, but apparently do not, that they must choose which to believe is valid. Both cannot be true.
Classical economists have no difficulty making the choice. A monetary phenomenon is one exhibited by the currency managed by the central bank. Inflation is always and everywhere a monetary phenomenon, and thus is a creature that lives and dies by the hand of the central banker.
This being the case, then who could believe that inflation is caused when the employment level rises above a “natural” rate? Apparently the demand-siders who guide the Fed believe it. So they choose as the Fed’s only inflation-fighting “tool” an interest rate target that provides no prospect of stabilizing the dollar’s value. The Fed actually wields the funds rate target as an instrument of fiscal policy to raise and lower the government-imposed cost of doing business, much as tax laws do.
As reflected in the St. Louis proceedings, the Fed uses the funds rate target to manage “aggregate demand.” By raising the funds rate target to reduce aggregate demand, the Fed aims to slow production, thereby increasing unemployment so wage-push inflationary pressures will be subdued.
Often Fed actions run directly contrary to congressional or executive branch fiscal policy. Demand-siders view this as a benefit of the “independent” Fed, so that expert economic planners are empowered to offset fiscal “excesses” of the elected branches of government.
Let’s be clear about why inflation is a monetary phenomenon and why inflation is not caused by employment. Inflation (or deflation) is a change in value of the monetary unit. Any such deterioration in monetary unit value must be worked through the entire pricing system of the economy to preserve the value of property, goods and services. The Fed can control the unit value of its currency; workers cannot control or affect the unit value of currency received as pay.
By treating the employment level as a purveyor of inflation, the Fed robs the labor market of the benefits of supply and demand signals. Oil, e.g., needs a trustworthy signal of a higher oil price to justify investment in more production. When labor is in short supply, the signal of higher wages will attract more workers. Meanwhile, workers who can provide the desired services during the shortage are entitled to gain from their market advantage. This does nothing to produce inflation. If workers are not permitted to gain in periods of labor shortage, the market will not work to supplement and replenish supply.
By slowing economic growth to produce higher unemployment, the Fed reduces demand for dollars in the productive economy without removing dollars from the system. This results in greater excess liquidity and more inflation. The Fed could hardly design a more counter-productive way of conducting itself.
As it produces inflation through creation of excess liquidity, the Fed impedes the validity of market price signals. Untrustworthy currency undercuts the supply message given by higher wages or prices. Labor is handicapped by bad money in this manner, as are all other goods and services. But labor is dealt a doubly damaging blow by the Fed’s erroneous embrace of Phillips curve theory, even as refined by Friedman. The Fed beats down any employment rate above what is perceived as “natural” by Phillips curve theorists.
Thus, the U.S. market for human services is furnished a deteriorating currency by the Fed. The Fed then acts to prevent the workers from adjusting to the changed currency value. Workers might choose to work more, or require more members of the household to work, to restore purchasing power. Regardless, the Fed acts with its funds rate target “tool” to slow economic growth and reduce employment opportunities.
This is unwise management of the most important central bank in the world, and a great disservice to all workers. The labor markets of the world cannot function fairly or efficiently under such irrational handicaps imposed by central planning.
When the unit value of the dollar is changing, the Fed cannot achieve price stability by managing the output gap by managing aggregate demand by managing the funds rate target. This chain of abstractions strung together by demand-side theorists to guide Fed practices ignores reality, without escaping it. When the dollar changes value, prices measured in dollars must be adjusted to maintain accurate, fair value in transactions.
The market supply/demand mechanism works best when the currency unit value does not change. To achieve currency value stability, the central bank must target the desired value and act directly to achieve it. Here, theoretical simplicity is to be admired, and will be rewarded with greater prosperity around the world.
The roundabout demand-side theory now dominant at the Fed and other central banks will not work. Flaws in use of the funds rate target itself are only part of the problem, but are significant. Here are the most significant flaws:
• The funds rate is not a controlling variable in the dollar’s value, so changing the funds rate produces no predictable change in the dollar’s value.
• Under Fed practices, raising the funds rate target does not actually “tighten” flow or quantity of dollar liquidity; it merely raises the cost of capital.
• The Fed cannot really control the funds rate target, since market pressures force the Fed to change the target against its wishes.
• The Fed’s attempts to control the funds rate cause market conditions to change in ways they would not otherwise, thereby destabilizing the dollar’s unit value.
The monetarist Anna Schwartz reported at St. Louis a consensus that “… there is no long-run trade-off between unemployment and inflation….” Indeed, demand-side economists do use this statement uniformly. Yet Goodfriend and Ball showcase the existing consensus supporting Friedman’s definition of the Phillips curve trade-off between unemployment and inflation.
Thus, denial of any long-run link between unemployment and inflation merely serves to mask the Fed’s practice of targeting a higher funds rate to reduce aggregate demand, slow economic growth and raise unemployment in the short-run to reduce inflation. One presently out of work would remind demand-siders, as Keynes did long ago, that “in the long-run we are all dead.”
Demand-side monetary theory is bankrupt, having no essentially valid core. The Phillips curve inflation-unemployment “trade-off” is theoretically absurd, and its effects are diabolical on workers at every income level. The Fed’s manipulation of the funds rate target destabilizes other market variables affecting the dollar’s value, so isolation of employment as inflation’s controlling variable is both logically indefensible and morally repugnant.
There being no true inflation-unemployment trade-off, the entire demand-side theory chain that aims to slow the economy is misconceived. There is no point to slowing the economy, since no theoretically sound reason exists to raise unemployment.
Though debate of monetary policy may seem esoteric to some, misery flowing from the errors discussed has many human faces. Service as the reserve currency of the world carries with it grave moral responsibilities. The standard of living of many societies – American, Mexican, Brazilian, Argentine, Korean, Thai, Chinese, Russian, African - has suffered greatly from the U.S. Federal Reserve’s failure to meet its duty to provide honest currency. The Fed’s use of complex oratory does not hide the inadequacy of its policy, nor does it meet America’s moral obligation to act uprightly as a nation.
The Fed’s management of the dollar has fallen short of American standards. Demand-side theory ought to be cast out of the Fed’s operations immediately, freeing central banks worldwide to follow sound monetary principles. What ought to replace it is a simple rule targeting the desired value of the dollar relative to gold. If the Fed will not do so, the President or the Congress should provide leadership. ~
- #6,647
- Jun 2, 2019 7:06am Jun 2, 2019 7:06am
- | Commercial User | Joined Dec 2014 | 14,164 Posts
https://bornoutsidethebox.com/2018/1...OlfBSjbc8bGRqs
Source: No More Fake News
by Jon Rappoport
December 31, 2018
Alert to pension fund managers all over the planet—and to everyone else—
“If 1,000 US and global pension fund managers start asking questions it could change everything – like stopping a nuclear war.”
That’s a statement from former US Assistant Secretary of Housing and Urban Development, and now president of Solari, Inc., Catherine Austin Fitts, who is a financial analyst like no other in our time.
Among other feats, she has identified a giant sucking black hole in the US government. And what has disappeared down that hole is money. Over the years, at least $20 trillion.
Unaccounted for.
Gone.
If you’re a pension fund manager, stop reading this article and immediately switch over to these two articles from Fitts: “The State of Our Pension Funds” and “’FASAB [Federal Accounting Standards Advisory Board] Statement 56′: Understanding New Government Financial Accounting Loopholes”.
You could begin to see a blinding light that changes your mind and changes your approach to the staggering debt your fund is dealing with. And in the process, you could help lead the way to a peaceful revolution. A far-reaching revolution, in which wide-ranging prosperity, not doom, sits up the road.
As for everyone else, here are a few of Fitts’ quotes from her mind-repairing article:
“So what is the problem? If it’s not a problem for $21 trillion to go missing from DOD and HUD, and, [if] it’s possible [for the government] to come up with more than $20[plus] trillion to give or loan to the banks [in a bailout] — when there is no legal obligation to do so, and, when we [the government] can transfer trillions of the most valuable technology in the world to private corporations at zero cost to them and [at] great cost to the taxpayers, [then] I assure you that fixing whatever pension fund problem there is, is not difficult. However, the political will must exist and want to. That is the problem.”
“If we can print money to give $20 trillion [plus] to the banks, and, [if we can] let $21 trillion go missing from the federal government, [then] why is it a problem to print $5 trillion to fund the pension funds?”
Failing pension funds are on the hook for $5 trillion (see also this short article from 2010), and the federal government has no answer? Well, that is a supreme con job, because, as Fitts points out, the government is playing far larger money games without a shred of concern.
And this is just the beginning of the rabbit hole Fitts has been traveling for the past several decades. Here is her basic position: Prosperity for the many, not the few, is eminently possible and doable.
Starting from that premise, and deploying her relentless skills as an analyst, she has discovered the strategies the government and mega-corporations have been deploying to undermine and torpedo an economically healthy society.
Finding and illuminating these strategies was not her basic intent. Her basic intent was lifting all boats for the citizenry. In pursuing that course, she came upon the secret obstructions.
And because her desire to help people did not waver in the slightest, she didn’t turn away. She exposed the obstructions. She continues to do so.
She writes: “Family wealth has the distinct advantage of returning control of investment decisions to individuals. However, this is hardly what the US establishment wants.”
“Our planetary governance and financial system currently operates significantly outside of the law. Whether the cost of war, organized crime, corruption, environmental damage, suppression of technology or secrecy, this lawlessness – and the lawlessness it encourages in the general population – represents a heavy and expensive drag on all aspects of our society, our economy and our landscape.”
Fitts cites an example of corporate choices in this lunatic money scam—General Electric: “By some estimates, its pension fund is underfunded to the tune of $31 billion. However, during the time its pension fund became so underfunded, GE spent $45 billion to buy back its publicly traded common stock. The needed funds were there at one point; it’s just that the leadership of the company decided to funnel it into stockholders’ hands rather than to the pensions of the employees who helped build the company.”
Do you have a pension fund manager? Do you know a pension fund manager? Link them to Fitts’ article. It’s long past the time when they can sit back and moan about the trouble they’re in. They need to learn about the underlying forces at work. (And if they’re a conscious part of the problem, let them learn that their game is exposed.)
Look around you. Money is everywhere. Titanic piles of it are flowing. The question is, to whom is it flowing, and how, and why? Within the current system, there are designated winners and losers. This has to do with criminal controllers posing as benefactors. They steer the money ship. They dump shipments of money at certain favored ports and keep shipments from reaching many other ports.
I know there are people out there who will say, “It’s all about the illegal Federal Reserve and the transnational bankers.” That’s like saying the drug problem is all about the Mexican cartels—but then, digging further, you also come across the expanding opium poppy fields in Afghanistan, the hands-off collusion in Chicago that permits the city to act as a primary hub for drug distribution in the US, the pharmaceutical companies that traffic millions of opioid pills to dealers, and the 2016 law that strangled DEA efforts to bust those companies.
The devil is in the details, and Fitts has uncovered an astonishing number of them.
I first came across her work about ten years ago, when we spoke several times about her specific method enabling local communities to discover money flows—the sources of money coming into their towns and cities, and the destinations of money going out. This brilliant tool would give communities the power to see exactly how money was impoverishing them, rather than enriching them. In an effort to make that tool widely available, thus pointing the way for communities to change those flows and foster local prosperity, Fitts ran into legal trouble with the federal government—and “trouble” is a vast understatement.
She emerged, after a long battle, with her primary goals securely intact.
She has answers and solutions.
Answers that are vital for our time.
Fitts was once an insider and had a front row seat at the money circus. Now, her ongoing enterprise is Solari, Inc. I highly recommend it to you.
[Related Solari Report post: Listen to Catherine Austin Fitts in conversation with Joseph P. Farrell as they discuss missing money, secret space program, the Vatican bank and other topics that tie into secrecy around money and control.]
Source: No More Fake News
by Jon Rappoport
December 31, 2018
Alert to pension fund managers all over the planet—and to everyone else—
“If 1,000 US and global pension fund managers start asking questions it could change everything – like stopping a nuclear war.”
That’s a statement from former US Assistant Secretary of Housing and Urban Development, and now president of Solari, Inc., Catherine Austin Fitts, who is a financial analyst like no other in our time.
Among other feats, she has identified a giant sucking black hole in the US government. And what has disappeared down that hole is money. Over the years, at least $20 trillion.
Unaccounted for.
Gone.
If you’re a pension fund manager, stop reading this article and immediately switch over to these two articles from Fitts: “The State of Our Pension Funds” and “’FASAB [Federal Accounting Standards Advisory Board] Statement 56′: Understanding New Government Financial Accounting Loopholes”.
You could begin to see a blinding light that changes your mind and changes your approach to the staggering debt your fund is dealing with. And in the process, you could help lead the way to a peaceful revolution. A far-reaching revolution, in which wide-ranging prosperity, not doom, sits up the road.
As for everyone else, here are a few of Fitts’ quotes from her mind-repairing article:
“So what is the problem? If it’s not a problem for $21 trillion to go missing from DOD and HUD, and, [if] it’s possible [for the government] to come up with more than $20[plus] trillion to give or loan to the banks [in a bailout] — when there is no legal obligation to do so, and, when we [the government] can transfer trillions of the most valuable technology in the world to private corporations at zero cost to them and [at] great cost to the taxpayers, [then] I assure you that fixing whatever pension fund problem there is, is not difficult. However, the political will must exist and want to. That is the problem.”
“If we can print money to give $20 trillion [plus] to the banks, and, [if we can] let $21 trillion go missing from the federal government, [then] why is it a problem to print $5 trillion to fund the pension funds?”
Failing pension funds are on the hook for $5 trillion (see also this short article from 2010), and the federal government has no answer? Well, that is a supreme con job, because, as Fitts points out, the government is playing far larger money games without a shred of concern.
And this is just the beginning of the rabbit hole Fitts has been traveling for the past several decades. Here is her basic position: Prosperity for the many, not the few, is eminently possible and doable.
Starting from that premise, and deploying her relentless skills as an analyst, she has discovered the strategies the government and mega-corporations have been deploying to undermine and torpedo an economically healthy society.
Finding and illuminating these strategies was not her basic intent. Her basic intent was lifting all boats for the citizenry. In pursuing that course, she came upon the secret obstructions.
And because her desire to help people did not waver in the slightest, she didn’t turn away. She exposed the obstructions. She continues to do so.
She writes: “Family wealth has the distinct advantage of returning control of investment decisions to individuals. However, this is hardly what the US establishment wants.”
“Our planetary governance and financial system currently operates significantly outside of the law. Whether the cost of war, organized crime, corruption, environmental damage, suppression of technology or secrecy, this lawlessness – and the lawlessness it encourages in the general population – represents a heavy and expensive drag on all aspects of our society, our economy and our landscape.”
Fitts cites an example of corporate choices in this lunatic money scam—General Electric: “By some estimates, its pension fund is underfunded to the tune of $31 billion. However, during the time its pension fund became so underfunded, GE spent $45 billion to buy back its publicly traded common stock. The needed funds were there at one point; it’s just that the leadership of the company decided to funnel it into stockholders’ hands rather than to the pensions of the employees who helped build the company.”
Do you have a pension fund manager? Do you know a pension fund manager? Link them to Fitts’ article. It’s long past the time when they can sit back and moan about the trouble they’re in. They need to learn about the underlying forces at work. (And if they’re a conscious part of the problem, let them learn that their game is exposed.)
Look around you. Money is everywhere. Titanic piles of it are flowing. The question is, to whom is it flowing, and how, and why? Within the current system, there are designated winners and losers. This has to do with criminal controllers posing as benefactors. They steer the money ship. They dump shipments of money at certain favored ports and keep shipments from reaching many other ports.
I know there are people out there who will say, “It’s all about the illegal Federal Reserve and the transnational bankers.” That’s like saying the drug problem is all about the Mexican cartels—but then, digging further, you also come across the expanding opium poppy fields in Afghanistan, the hands-off collusion in Chicago that permits the city to act as a primary hub for drug distribution in the US, the pharmaceutical companies that traffic millions of opioid pills to dealers, and the 2016 law that strangled DEA efforts to bust those companies.
The devil is in the details, and Fitts has uncovered an astonishing number of them.
I first came across her work about ten years ago, when we spoke several times about her specific method enabling local communities to discover money flows—the sources of money coming into their towns and cities, and the destinations of money going out. This brilliant tool would give communities the power to see exactly how money was impoverishing them, rather than enriching them. In an effort to make that tool widely available, thus pointing the way for communities to change those flows and foster local prosperity, Fitts ran into legal trouble with the federal government—and “trouble” is a vast understatement.
She emerged, after a long battle, with her primary goals securely intact.
She has answers and solutions.
Answers that are vital for our time.
Fitts was once an insider and had a front row seat at the money circus. Now, her ongoing enterprise is Solari, Inc. I highly recommend it to you.
[Related Solari Report post: Listen to Catherine Austin Fitts in conversation with Joseph P. Farrell as they discuss missing money, secret space program, the Vatican bank and other topics that tie into secrecy around money and control.]
- #6,648
- Jun 2, 2019 7:10am Jun 2, 2019 7:10am
- | Commercial User | Joined Dec 2014 | 14,164 Posts
https://bornoutsidethebox.com/2018/1...LP4RQr7l5ZYG2Y
Source: Richard Dolan
Published on Nov 8, 2018
https://img.youtube.com/vi/WlItNAk4U...resdefault.jpg
Recorded November 7, 2018, Richard Dolan interviews Catherine Austin Fitts.
This is a fascinating and extremely clear discussion of the nature of the $21 trillion of “unaccounted discrepancies” in the Pentagon and HUD budgets from 1998 to 2015. Catherine argues that the fundamentals in how we look at the U.S. federal budget and spending is completely wrong, and our society is bleeding money on a daily basis to fund unaccountable programs that do not benefit the people.
Catherine Austin Fitts is one of the world’s leading experts in “black budget economics,” and has been investigating U.S. federal government financial discrepancies totaling in the trillions of dollars. She was Assistant Secretary of Housing and Urban Development from 1989 to 1993, and is an investment analyst and advisor. She has authored many articles on financial fraud, missing money, and the structure of power in our world.
See her websites at:
https://home.solari.com/
https://missingmoney.solari.com/
More from my site
Source: Richard Dolan
Published on Nov 8, 2018
https://img.youtube.com/vi/WlItNAk4U...resdefault.jpg
Recorded November 7, 2018, Richard Dolan interviews Catherine Austin Fitts.
This is a fascinating and extremely clear discussion of the nature of the $21 trillion of “unaccounted discrepancies” in the Pentagon and HUD budgets from 1998 to 2015. Catherine argues that the fundamentals in how we look at the U.S. federal budget and spending is completely wrong, and our society is bleeding money on a daily basis to fund unaccountable programs that do not benefit the people.
Catherine Austin Fitts is one of the world’s leading experts in “black budget economics,” and has been investigating U.S. federal government financial discrepancies totaling in the trillions of dollars. She was Assistant Secretary of Housing and Urban Development from 1989 to 1993, and is an investment analyst and advisor. She has authored many articles on financial fraud, missing money, and the structure of power in our world.
See her websites at:
https://home.solari.com/
https://missingmoney.solari.com/
More from my site
-
- https://bornoutsidethebox.com/wp-con...ed-300x164.pngThe Pentagon’s Missing Trillions: What You Need to Know
- https://bornoutsidethebox.com/wp-con...ze-300x169.jpgMSM Covers Up $21 Trillion Historic Government Fraud – Dr. Mark Skidmore
- https://bornoutsidethebox.com/wp-con...ed-300x167.jpgOn Personal Coherence & the Reluctance to Become Free Individuals
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- https://bornoutsidethebox.com/wp-con...20-300x138.jpgCatherine Austin Fitts: Global Control & the Black Budget
- https://bornoutsidethebox.com/wp-con...ed-300x167.jpgRichard Dolan & Joseph P. Farrell: UFOs, Nazis, Missing Money, 9/11, Antarctica and More
- https://bornoutsidethebox.com/wp-con...ed-300x166.jpgBreakaway Truth: A Tale of Two Civilizations
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- https://bornoutsidethebox.com/wp-con...20-300x180.jpgCatherine Austin Fitts on Global Control & Bitcoin
- https://bornoutsidethebox.com/wp-con...ed-300x169.jpgBillions Missing from Russian Space Agency
- https://bornoutsidethebox.com/wp-con...ed-300x166.jpgCatherine Austin Fitts: Missing Trillions & the Secret Space Force Economy
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- https://bornoutsidethebox.com/wp-con.../thumbs/23.jpgThe Government “Can’t Find” $20 Trillion, While Pension Funds are Tanking
- https://bornoutsidethebox.com/wp-con...c/thumbs/1.jpgThe Government “Can’t Find” $20 Trillion, While Pension Funds are Tanking
- https://bornoutsidethebox.com/wp-con...to-300x168.jpgA Perfect Nightmare: Cryptoklepto
- Load more posts
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Richard Dolan
Richard Dolan is one of the world’s leading researchers and writers on the subject of UFOs, and believes that they constitute the greatest mystery of our time. He is the author of two volumes of history, UFOs and the National Security State, both ground-breaking works which together provide the most factually complete and accessible narrative of the UFO subject available anywhere. He also co-authored a speculative book about the future, A.D. After Disclosure, the first-ever analysis not only of how UFO secrecy might end, but of the all-important question: what happens next?
Sign up for Richard’s weekly newsletter.
https://www.richarddolanpress.com/
- #6,649
- Jun 2, 2019 7:23am Jun 2, 2019 7:23am
- | Commercial User | Joined Dec 2014 | 14,164 Posts
https://constitution.solari.com/fasa...OD8fTwv1_OnkkI
FASAB Statement 56: Understanding New Government Financial Accounting Loopholes
January 10, 2019 Solari Staff Articles 13
https://constitution.solari.com/wp-c...-1030x438.jpeg
Table of Contents
I. Introduction
II. History of the Federal Accounting Standards Advisory Board (FASAB)
III. FASAB and Standard 56
A. What Does Standard 56 Do?
B. Reporting Entities Within the Scope of Standard 56
C. Changes to Disclosure Standards Under Standard 56
D. Modifications to Avoid Disclosure of Classified Information
E. Reporting on Consolidation Entities
F. Interpretations Modifying Reporting Standards in the Future
IV. Administrative History of Statement 56
A. Commentary on Required Disclaimers
B. Federal Commentary on Standard 56 Generally
C. Concerns From Accounting Firms
V. The Results of Statement 56 for the Public
VI. About Us
December 29, 2018
I. Introduction
Financial accountability for the government is a cornerstone of a functioning representative democracy. The ability for the people to know where taxpayer money goes to is crucial to having an informed opinion regarding the actions of your representatives and to react accordingly. Unfortunately, as we’ve discussed in previous articles, the current state of government accounting is far from ideal–often bordering on useless to the public. This is largely due to lax enforcement of existing laws such as the Chief Financial Officers (CFO) Act, but also stems from the very real tension between completely transparent government financial disclosure and national security interests (see The U.S. Statutes Creating Modern Constitutional Financial Management and Reporting Requirements and the Government’s Failure to Follow Them, available at https://constitution.solari.com/the-...o-follow-them/). As of the last few months, this tension has taken the future of government financial disclosure to the public to new levels of opacity. The Federal Accounting Standards Advisory Board (FASAB) has released Statement of Federal Financial Accounting Standards 56 (Standard 56), taking government accounting practices from laxly enforced reporting standards to a new benchmark entirely–expressly approved obfuscation of reporting and, in some cases, outright concealing financials.
This sounds fairly alarmist at first blush but, simply put, Standard 56 creates a set of situations where government entities may move numbers around to conceal where money is actually spent or even not report spending outright. Many of the concepts in Standard 56 are not new and have been discussed in FASAB reports for nearly a decade. However, these new changes make a substantial portion of government financial reporting so unreliable as to not be a useful tool to the public (see FASAB Statement of Federal Financial Accounting Standards 56, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
In order to fully understand Standard 56, we will be taking a fairly deep dive on the new accounting standards it creates—from the history leading up to the new rules, to summarizing the exact changes of Standard 56. We’ve said that Standard 56 isn’t new, and this is true; it has hundreds and hundreds of pages of memorandums and the like which came before it, outlining the exact parameters of these new reporting rules. For that reason, a complete summary of what a government entity must report will not be possible–or likely even useful–in an article of this length. That being said, we will explore the role of FASAB itself, the functional changes of Standard 56, and how it will impact the ability of the U.S. taxpayer to see how their money is spent.
II. History of the Federal Accounting Standards Advisory Board (FASAB)
FASAB came about as a response to the requirements of the CFO Act. We previously wrote about the CFO Act in The U.S. Statutes Creating Modern Constitutional Financial Management and Reporting Requirements and the Government’s Failure to Follow Them (available at https://constitution.solari.com/the-...o-follow-them/). Under the Act, the individual CFOs of covered federal agencies are responsible for preparing financial statements for regular audit in order to ensure accuracy in accounting. The CFOs also were tasked by the Act with integrating accounting and budget information into a form consistent with those used to make budgets, put together a uniform financial management system for their agency, and–perhaps most importantly–make sure that the system they put together allowed for actual useful measurement of the financial performance of the CFO’s agency.
However, the CFO Act was light on the details, and after the Act passed in 1990, there was a need to determine the actual details of the accounting standards required. Therefore, the Treasury, OMB, and Comptroller General signed a Memorandum jointly establishing the FASAB to “consider and recommend the appropriate accounting standards for the federal government” (see History of FASAB, available at http://www.fasab.gov/the-history-of-fasab/). Until 1999, FASAB simply gave recommendations to those three sponsoring entities. Then, in 1999, FASAB was approved to set final generally acceptable accounting practices (GAAP) for the federal government, with only a 90 day review period by the sponsoring entities. In 2002, the Treasury was removed as a sponsoring entity, leaving the OMB and GAO as the only entities able to object to FASAB set standards (see id.).
III. FASAB and Standard 56
As mentioned above, since 1999, FASAB sets the final GAAP for the federal government. These practices are then used throughout the federal government to determine the content and structure of the financial reports the CFO Act requires federal government agencies, departments, and the like to prepare. While the GAAP are not themselves literally binding law, they do show what the federal government considers to be compliance with the law. As long as an agency follows GAAP, there will generally be a presumption that it is also complying with the federal financial accounting requirements. Therefore, unless the underlying legislation is amended by Congress, FASAB essentially determines the extent of the federal government’s financial transparency (see id.). With the official adoption of Standard 56 as of October 4, 2018–completely unchanged from the pre-comment period version from July 2018–FASAB has determined that national security concerns essentially trump the need for financial transparency to the public. So how does Standard 56 do this?
A. What Does Standard 56 Do?
In the absolute most simple terms, Standard 56 allows federal entities to shift amounts from line item to line item and sometimes even omit spending altogether when reporting their financials in order to avoid the potential of revealing classified information.1 However, as with all laws, nearly every word in that sentence is a complicated concept to unpack. Who counts as a federal reporting entity? When and how can these entities conceal or remove financial information from their reports? What information can be removed? When does something count as confidential, and who makes that determination? All of these questions have enormous bodies of writing in FASAB memorandums addressing, and sometimes failing to address, their answers.
The simplest place to start with understanding Standard 56 is its scope. It applies to federal entities that issue unclassified general purpose federal financial reports (GPFFR), including where one entity is consolidated with another. This means it only applies to otherwise unclassified financial reports where there is a risk of revealing classified information; classified financial reports are their own can of worms. (See generally, FASAB Statement of Federal Financial Accounting Standards 56, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf). Standard 56 also doesn’t remove the actual requirement to report, it just allows these entities to change their reports in ways that don’t reflect their actual spending (see id.). However, for the purposes of government transparency, determining who is responsible for classifying information, and/or removing that information from unclassified reports, is quite opaque for the average interested citizen.
B. Reporting Entities Within the Scope of Standard 56
The actual reporting entities empowered by the standards of Standard 56 include organizations which are included in the government wide GPFFR (see id.). This includes any entities that are “(1) budgeted for by elected officials of the federal government, (2) owned by the federal government, or (3) controlled by the federal government with risk of loss or expectation of benefits” (FASAB Statement of Federal Financial Accounting Standards 47, p. 1, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf).
However, many different departments, bureaus, and agencies prepare their own GPFFRs as well. The various entities that both prepare their own GPFFR and are within a larger reporting entity are called Component Reporting Entities. This includes executive departments, independent agencies, government corporations, legislative agencies, and federal courts (id. at 7). Their GPFFRs are then consolidated into the government wide GPFFR.
Under the Component Reporting Entities and included in their GPFFRs are various other organizations, from smaller departments to government contractors, which are split into two categories: disclosure entities and consolidation entities (see id.).
Consolidation entities are entities like agencies and departments. A consolidation entity generally (1) is financed through taxes and other non-exchange revenues, (2) is governed by the Congress and/or the President, (3) imposes or may impose risks and rewards to the federal government, and (4) provides goods and services on a non-market basis (see id. at 16). For instance, a department or corporation established by Congress to perform a government function is a classic example of a consolidation entity. Consolidated entities are reported by a larger entity as part and parcel of their financial reporting–as if they were one economic entity. We will discuss this type of entity later in great depth, as it constitutes one of the largest potential loopholes of Standard 56 (see id.).
Disclosure entities are financially independent organizations. These organizations still need to be included in the government wide GPFFR, but do not fully meet the four characteristics of consolidated entities above. They include quasi-governmental entities, organizations in receiverships and conservatorships, and organizations owned or controlled through federal government intervention actions (see id. at 16). A good example would be government-established non-profits that have a significant portion of their board appointed by the President but are entirely funded by their own activities.
Additionally, there are “related parties,” which are organizations where at least one of the parties involved has the ability to exercise significant influence over the policy decisions of the other party. This significant influence does not need to amount to control, but can include things such as representation on a board of directors, participation in policy making procedures, shared managerial personnel, and things along those lines. The existence of significant influence is generally determined through a full analysis of the particulars of each situation. This classification is usually applied to organizations that do not even rise to the level of a disclosure entity, but nonetheless would be misleading to exclude. Some common examples of related parties are some government-sponsored enterprises and organizations governed by representatives from each of the governments that created the organization, including the United States, wherein the federal government has agreed to ongoing or contingent financial support to accomplish shared objectives. Related entities generally do not include government contractors, government vendors, some non-profits, organizations created by treaty, or special interest groups–although they can in the right circumstances (see id. at 7 and 31-33).
However, there are also certain entities that would probably be consolidation or disclosure entities, but are expressly excluded from the government wide GPFFR: the Federal Reserve System and bailout entities (see Financial Report of the United States Government 2016, p. 227, available at https://fiscal.treasury.gov/files/re...FR-(Final).pdf). In particular, this includes entities like Freddie Mac and Fannie Mae (see id.). If the government obtains rights in another entity which would give them the sort of control that normally makes a disclosure entity, but gains those rights when it “guarantee[s] or pay[s] debt for a privately owned entity whose failure could have an adverse impact on the nation’s economy, commerce, national security, etc. . .” those rights don’t count for determining a reporting entity (id).
This means that in addition to consolidation and disclosure entities, the scope of Standard 56 stretches to any organization which it would be misleading to exclude but isn’t otherwise incorporated into their list of covered entities. Because of this, although there is not a exhaustive list of whose financial reporting is impacted by Standard 56, if you can think of an entity related to the government, it is a safe bet they count as a covered reporting entity. This can include publicly traded corporations with significant funding and/or control from the federal government.
C. Changes to Disclosure Standards Under Standard 56
For these covered entities, Standard 56 offers financial reporting exceptions in a few situations for national security purposes. These reporting exceptions are the meat of Standard 56, three rules substantially modifying the reporting requirements of the above discussed entities to varying degrees (see FASAB Statement of Federal Financial Accounting Standards 56, p. 6, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
In general, disclosure entities are required to provide their financial reporting in a manner which is clear, concise, meaningful, and transparent (see FASAB Statement of Federal Financial Accounting Standards 47, para 71-73, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf). This is done through a single, integrated report of finances disclosing the relationship of the organization to the government and related entities, the nature and magnitude of their activity and their financial balances, and a description of financial and non-financial risks, potential benefits, and, if possible, the amount of the federal government’s exposure to gains and losses from the past or future operations of the disclosure entity or entities (see id. at para 74). This generally includes how much control or influence over the entity is exercised, key terms in their contractual agreements, percentage ownership and voting rights, a summary of assets, liabilities, revenues, expenses, gains and losses, key financial indicators, information on how their reports are stored and can be obtained, and quite a bit more (see id.). Essentially what is required is a transparent summary of how money is spent to provide accountability to the public. Standard 56 creates three loopholes to this disclosure standard.
D. Modifications to Avoid Disclosure of Classified Information
The first new loophole allows disclosure entities to modify their financial reports to “prevent the disclosure of classified information in an unclassified GPFFR” so long as these modifications do not change the net results of operations and net position. (See FASAB Statement of Federal Financial Accounting Standards 56, p. 6, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
This ultimately means that, when done to conceal confidential information, entities can–and are essentially required to under the terms of Standard 56–shift money from one line item to another so long as the totals stay consistent. The rule also allows entities to omit the line item entirely while retaining the amounts so as to maintain the same net results. This means that readers of these reports will never know if the amounts reported spent on specific projects or things are an accurate representation (see id.). As you might expect given the rationale of this being a national security precaution, there will not be any narrative in these reports explaining or revealing where a modification has taken place (see id.). If they can maintain net position in their reports, an entity can even omit a project entirely by folding it into another department or project within the same entity.
While it could obviously be worse for transparency purposes, the alternative would be that the amounts would just be omitted entirely. That brings us to the next two changes to accounting standards created by Standard 56.
E. Reporting on Consolidation Entities
We briefly discussed consolidation entities above as one of the larger loopholes to reporting within Standard 56. This is because the second change to reporting requirements of Standard 56 allows the reporting entity which the consolidation entity is consolidated with to modify reports to avoid disclosure of confidential information even if that modification changes net results of operations or net position. The reporting entity can move the financials of the consolidation entity or even choose not to include it in its report; full stop. (See FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
The concept of consolidation entities being incorporated into the reports of a larger reporting entity is far from new. FASAB has memorandums detailing the rules regarding consolidation from as far back as 2012 (see FASAB Federal Reporting Entity Memorandum, November 29, 2012, available at http://files.fasab.gov/pdffiles/tab_...al_2012dec.pdf). By itself, it is not a particularly problematic issue. Under FASAB rules, consolidation in financial reporting is appropriate for those organizations financed by the taxpayer, governed by elected or appointed officials, imposing risks and rewards on the taxpayer, and providing goods and services on a non-market basis. However, consolidation is not appropriate for organizations operating with a high degree of autonomy (see id. at 7).
In general, where an organization is controlled by the federal government and stands to make or lose money, but doesn’t have enough independence for a disclosure entity, it is included somewhere as a consolidation entity (see FASAB Statement of Federal Financial Accounting Standards 47, pp. 14-15, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf). As you’ve seen, the determination of what sort of entity something is hinges a great deal on the level of autonomy of the entity–the greater the control the government has, the more likely something will be classified as a consolidation entity. This control doesn’t mean the government has to actively manage on the day-to-day, but does require an examination of–among other things–whether the government can do things like appoint a majority of board members, dissolve the organization, authorize or deny action within the organization on some or all issues, or direct the policies or use of assets within the organization, and/or direct investment decisions. Consolidation entities are only assigned to one component entity and, in general, where that sort of control exists for a consolidated entity, the public would rely on the larger reporting entity for information on the consolidation entity’s financials (see id.). Under the second accounting standard change within Standard 56, the public can’t even count on these financials being reported in the first place (see FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7).
F. Interpretations Modifying Reporting Standards in the Future
The final change to accounting standards within Standard 56 doesn’t do much at the moment, but has the greatest potential to undermine financial transparency in the future. It allows FASAB to issue Interpretations of Standard 56 in the future which would allow other modifications to financial reports for the purpose of avoiding disclosure of classified information. FASAB can, and likely will, release these Interpretations over time. These Interpretations can allow modifications to reporting without regard for maintaining an entity’s net results or net position in their reporting. Those interpretations may even be classified themselves (Appendix A, A16), resulting in a portion of the federal government’s accountability standards being concealed from the public (see FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7).
Looked at in the most optimistic light, this will allow FASAB to ensure that Standard 56 isn’t abused and issue rulings of when disclosure is necessary in situations not yet considered. Looked at in a less optimistic light, this means that the ability of the government to obfuscate financial records will continue to grow in the coming months and years, without public oversight, as Interpretations add to or clarify these existing loopholes.
IV. Administrative History of Statement 56
Statement 56, and its reporting exceptions, have been in the works within FASAB for months. When an issue is identified, FASAB performs preliminary deliberations, prepares the initial documents, and then releases a review version to the public for comment and public hearings. After the comment period, FASAB enters further deliberations to consider the comments and make revisions. Then, the Board approves the proposed statement by a two-thirds majority vote, and submits it to the principals (the OMB and the GAO) for review. If neither principal objects to the proposal after 90 days, it is published by FASAB and is added to the GAAP for federal entities (Definition: FASAB (Federal Accounting Standards Advisory Board), available at https://searchcompliance.techtarget....Advisory-Board).
For Standard 56, the exposure draft was published on July 12, 2018, with comments due by August 13, 2018. Seventeen comments were submitted by various departments, agencies, and accounting firms (see FASAB Classified Activities, available at http://fasab.gov/ca/). The final Statement 56 was published on October 4, 2018, with little if any change from the exposure draft. However, the comments on Statement 56 are themselves interesting and somewhat enlightening.
A. Commentary on Required Disclaimers
FASAB proposed two possible alternatives for disclosure/disclaimer requirements under Standard 56. Either reporting entities could be given a choice in whether or not to consistently disclose that certain presentations may have been modified, or all reporting entities must disclose the possibility that certain presentations may have been modified, regardless of actual modification (see FASAB Exposure Draft Interpretation of Federal Financial Accounting Standards 56: Classified Activities, available at https://fas.org/sgp/news/2018/07/fasab-review.pdf).
The SEC gave a fairly entertaining comment on Standard 56. After answering “No Comment” to literally every preceding question, the SEC gave its thoughts on FASAB’s proposal for how component entities should disclose that they have modified their reports. The SEC, the nation’s foremost agency in the fight against financial fraud, doesn’t think that every component entity should have to disclose that modifications may have occurred, and especially the SEC shouldn’t have to. The reasoning the SEC gave for this position was that they “believe that this would be misleading and likely to cause confusion for financial statement readers, by implying that SEC is involved in classified activities. It’s likely that SEC, as well as other agencies, would receive numerous inquiries from the public and from the media by including such an unexpected disclaimer in its financial statements.” In other words, they’re worried it would look strange to the public if they disclosed that they had modified their financial reporting, despite no such modification. The public may think it odd that component entities such as the SEC would make such a, in their own words, “unexpected disclaimer” (FASAB Exposure Draft: Classified Activities, SEC Comment, available at http://files.fasab.gov/pdffiles/CA_13_SEC.PDF).
Veterans Affairs and the Association of Government Accountants had a similar stance, and while they commented on other aspects of Standard 56 as well, they joined the SEC in criticizing a mandatory disclaimer, and suggested disclaimers would only be appropriate when GPFFRs were actually modified (see FASAB Classified Activities, available at http://fasab.gov/ca/).
Several other commenting parties had a different take on the required disclaimers. For instance, the Department of Defense’s Office of The Chief Financial Officer and the Department of the Interior wanted agencies to have the option to give a disclaimer or not, irregardless of whether or not they made changes to classified information under the new standard (id.). The Department of Energy’s Office of The Chief Financial Officer even felt it would be appropriate to have no disclaimers whatsoever, even if GPFFRs were materially modified (id.).
B. Federal Commentary on Standard 56 Generally
Various government agencies commented on the “meat” of Standard 56, and most were in favor2 of FASAB’s proposals in general. For instance, Housing and Urban Development had fairly positive comments across the board, and deferred greatly to the need to classify information. The organization agreed with all of FASAB’s methodology and conclusions, and stated the new standards would strike a correct balance between protecting classified information and a commitment to open government.
However, oddly enough, the Department of Defense Office of the Inspector General was particularly concerned with the proposed Statement. They wrote “[t]his proposed guidance is a major shift in Federal accounting guidance and, in our view, the potential impact is so expansive that it represents another comprehensive basis of accounting” (FASAB Exposure Draft: Classified Activities, Department of Defense Office of the Inspector General Comment, available at http://files.fasab.gov/pdffiles/CA_8_DoD_OIG.PDF). They suggested already existing methods like redaction are sufficient to protect classified information, and stated the FASAB “should clarify whether this proposed standard, or subsequent Interpretations, could permit entities to record misstated amounts in the financial statements to mislead readers with the stated purpose of protecting classified information. We believe that no accounting guidance should allow this type of accounting entry” (id.).
Additionally, while not quite as critical as the Inspector General, the Treasury expressed concerns about the modification of net results of operations and net position.
C. Concerns From Accounting Firms
The accounting firm Kearney & Company had a more critical take on the proposed standard as well. They worried that “[t]he FASAB’s proposed approach could result in material omissions in GPFFR. . . If GPFFR can be modified so material activity is no longer accurately presented to the reader of financial statements, its usefulness to public users is limited and subject to misinterpretation” (FASAB Exposure Draft: Classified Activities, Kearney & Company Comment, available at: http://files.fasab.gov/pdffiles/CA_14_Kearney_&_CO_.PDF).
The accounting firm KPMG was more concerned with clarity and consistency, stating that because of potential classified interpretations, only some people with clearance will be able to understand the complete set of GAAP. Because of this, “[i]t is not clear how management of each federal entity will be able to assert that their GPFFR have been prepared in accordance with GAAP when management does not have access to all of GAAP” (FASAB Exposure Draft: Classified Activities, KPMG Comment, available at http://files.fasab.gov/pdffiles/CA_2_KPMG.PDF).
V. The Results of Statement 56 for the Public
There is a legitimate existing tension between the need to protect confidential government information and the public’s interest in financial transparency and accountability. Standard 56 isn’t without possible justification. That being said, the concerns of both the accounting world and many within the federal government itself are extremely valid.
Statement 56 undercuts the reliability of government accounting standards and financial statements to such a degree as to render an already questionably valuable reporting tool virtually useless to the public. The possibility of false or omitted information renders the reports largely unreliable as to actual amounts, as does the fact that even an accurate report is rendered questionable by the very existence of modifications that are not necessarily exposed. Classifying portions of the federal GAAP mystifies the process even further, and the fuzzy definitions of reporting entities leaves the potential for this to touch not only direct government entities, but government contractors and other private (but federally entangled) entities. The general disclosure of the government–requiring all reporting entities to report the potential of modifications whether or not they actually exist in their report while simultaneously forbidding the actual disclosure of the actual existence of any modifications–is essentially a worst case in terms of transparency for the public.
VI. About Us
This article was written and edited by Michele Ferri and Jonathan Lurie of The Law Offices of Lurie and Ferri for use by The Solari Report. Michele Ferri and Jonathan Lurie are both practicing attorneys out of California. The Law Offices of Lurie and Ferri focus on working with start-up businesses as well as on intellectual property and business law issues. They can be found at http://www.lflawoffices.com/ or contacted at [email protected].
Sources
FASAB Statement 56: Understanding New Government Financial Accounting Loopholes
January 10, 2019 Solari Staff Articles 13
https://constitution.solari.com/wp-c...-1030x438.jpeg
Table of Contents
I. Introduction
II. History of the Federal Accounting Standards Advisory Board (FASAB)
III. FASAB and Standard 56
A. What Does Standard 56 Do?
B. Reporting Entities Within the Scope of Standard 56
C. Changes to Disclosure Standards Under Standard 56
D. Modifications to Avoid Disclosure of Classified Information
E. Reporting on Consolidation Entities
F. Interpretations Modifying Reporting Standards in the Future
IV. Administrative History of Statement 56
A. Commentary on Required Disclaimers
B. Federal Commentary on Standard 56 Generally
C. Concerns From Accounting Firms
V. The Results of Statement 56 for the Public
VI. About Us
December 29, 2018
I. Introduction
Financial accountability for the government is a cornerstone of a functioning representative democracy. The ability for the people to know where taxpayer money goes to is crucial to having an informed opinion regarding the actions of your representatives and to react accordingly. Unfortunately, as we’ve discussed in previous articles, the current state of government accounting is far from ideal–often bordering on useless to the public. This is largely due to lax enforcement of existing laws such as the Chief Financial Officers (CFO) Act, but also stems from the very real tension between completely transparent government financial disclosure and national security interests (see The U.S. Statutes Creating Modern Constitutional Financial Management and Reporting Requirements and the Government’s Failure to Follow Them, available at https://constitution.solari.com/the-...o-follow-them/). As of the last few months, this tension has taken the future of government financial disclosure to the public to new levels of opacity. The Federal Accounting Standards Advisory Board (FASAB) has released Statement of Federal Financial Accounting Standards 56 (Standard 56), taking government accounting practices from laxly enforced reporting standards to a new benchmark entirely–expressly approved obfuscation of reporting and, in some cases, outright concealing financials.
This sounds fairly alarmist at first blush but, simply put, Standard 56 creates a set of situations where government entities may move numbers around to conceal where money is actually spent or even not report spending outright. Many of the concepts in Standard 56 are not new and have been discussed in FASAB reports for nearly a decade. However, these new changes make a substantial portion of government financial reporting so unreliable as to not be a useful tool to the public (see FASAB Statement of Federal Financial Accounting Standards 56, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
In order to fully understand Standard 56, we will be taking a fairly deep dive on the new accounting standards it creates—from the history leading up to the new rules, to summarizing the exact changes of Standard 56. We’ve said that Standard 56 isn’t new, and this is true; it has hundreds and hundreds of pages of memorandums and the like which came before it, outlining the exact parameters of these new reporting rules. For that reason, a complete summary of what a government entity must report will not be possible–or likely even useful–in an article of this length. That being said, we will explore the role of FASAB itself, the functional changes of Standard 56, and how it will impact the ability of the U.S. taxpayer to see how their money is spent.
II. History of the Federal Accounting Standards Advisory Board (FASAB)
FASAB came about as a response to the requirements of the CFO Act. We previously wrote about the CFO Act in The U.S. Statutes Creating Modern Constitutional Financial Management and Reporting Requirements and the Government’s Failure to Follow Them (available at https://constitution.solari.com/the-...o-follow-them/). Under the Act, the individual CFOs of covered federal agencies are responsible for preparing financial statements for regular audit in order to ensure accuracy in accounting. The CFOs also were tasked by the Act with integrating accounting and budget information into a form consistent with those used to make budgets, put together a uniform financial management system for their agency, and–perhaps most importantly–make sure that the system they put together allowed for actual useful measurement of the financial performance of the CFO’s agency.
However, the CFO Act was light on the details, and after the Act passed in 1990, there was a need to determine the actual details of the accounting standards required. Therefore, the Treasury, OMB, and Comptroller General signed a Memorandum jointly establishing the FASAB to “consider and recommend the appropriate accounting standards for the federal government” (see History of FASAB, available at http://www.fasab.gov/the-history-of-fasab/). Until 1999, FASAB simply gave recommendations to those three sponsoring entities. Then, in 1999, FASAB was approved to set final generally acceptable accounting practices (GAAP) for the federal government, with only a 90 day review period by the sponsoring entities. In 2002, the Treasury was removed as a sponsoring entity, leaving the OMB and GAO as the only entities able to object to FASAB set standards (see id.).
III. FASAB and Standard 56
As mentioned above, since 1999, FASAB sets the final GAAP for the federal government. These practices are then used throughout the federal government to determine the content and structure of the financial reports the CFO Act requires federal government agencies, departments, and the like to prepare. While the GAAP are not themselves literally binding law, they do show what the federal government considers to be compliance with the law. As long as an agency follows GAAP, there will generally be a presumption that it is also complying with the federal financial accounting requirements. Therefore, unless the underlying legislation is amended by Congress, FASAB essentially determines the extent of the federal government’s financial transparency (see id.). With the official adoption of Standard 56 as of October 4, 2018–completely unchanged from the pre-comment period version from July 2018–FASAB has determined that national security concerns essentially trump the need for financial transparency to the public. So how does Standard 56 do this?
A. What Does Standard 56 Do?
In the absolute most simple terms, Standard 56 allows federal entities to shift amounts from line item to line item and sometimes even omit spending altogether when reporting their financials in order to avoid the potential of revealing classified information.1 However, as with all laws, nearly every word in that sentence is a complicated concept to unpack. Who counts as a federal reporting entity? When and how can these entities conceal or remove financial information from their reports? What information can be removed? When does something count as confidential, and who makes that determination? All of these questions have enormous bodies of writing in FASAB memorandums addressing, and sometimes failing to address, their answers.
The simplest place to start with understanding Standard 56 is its scope. It applies to federal entities that issue unclassified general purpose federal financial reports (GPFFR), including where one entity is consolidated with another. This means it only applies to otherwise unclassified financial reports where there is a risk of revealing classified information; classified financial reports are their own can of worms. (See generally, FASAB Statement of Federal Financial Accounting Standards 56, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf). Standard 56 also doesn’t remove the actual requirement to report, it just allows these entities to change their reports in ways that don’t reflect their actual spending (see id.). However, for the purposes of government transparency, determining who is responsible for classifying information, and/or removing that information from unclassified reports, is quite opaque for the average interested citizen.
B. Reporting Entities Within the Scope of Standard 56
The actual reporting entities empowered by the standards of Standard 56 include organizations which are included in the government wide GPFFR (see id.). This includes any entities that are “(1) budgeted for by elected officials of the federal government, (2) owned by the federal government, or (3) controlled by the federal government with risk of loss or expectation of benefits” (FASAB Statement of Federal Financial Accounting Standards 47, p. 1, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf).
However, many different departments, bureaus, and agencies prepare their own GPFFRs as well. The various entities that both prepare their own GPFFR and are within a larger reporting entity are called Component Reporting Entities. This includes executive departments, independent agencies, government corporations, legislative agencies, and federal courts (id. at 7). Their GPFFRs are then consolidated into the government wide GPFFR.
Under the Component Reporting Entities and included in their GPFFRs are various other organizations, from smaller departments to government contractors, which are split into two categories: disclosure entities and consolidation entities (see id.).
Consolidation entities are entities like agencies and departments. A consolidation entity generally (1) is financed through taxes and other non-exchange revenues, (2) is governed by the Congress and/or the President, (3) imposes or may impose risks and rewards to the federal government, and (4) provides goods and services on a non-market basis (see id. at 16). For instance, a department or corporation established by Congress to perform a government function is a classic example of a consolidation entity. Consolidated entities are reported by a larger entity as part and parcel of their financial reporting–as if they were one economic entity. We will discuss this type of entity later in great depth, as it constitutes one of the largest potential loopholes of Standard 56 (see id.).
Disclosure entities are financially independent organizations. These organizations still need to be included in the government wide GPFFR, but do not fully meet the four characteristics of consolidated entities above. They include quasi-governmental entities, organizations in receiverships and conservatorships, and organizations owned or controlled through federal government intervention actions (see id. at 16). A good example would be government-established non-profits that have a significant portion of their board appointed by the President but are entirely funded by their own activities.
Additionally, there are “related parties,” which are organizations where at least one of the parties involved has the ability to exercise significant influence over the policy decisions of the other party. This significant influence does not need to amount to control, but can include things such as representation on a board of directors, participation in policy making procedures, shared managerial personnel, and things along those lines. The existence of significant influence is generally determined through a full analysis of the particulars of each situation. This classification is usually applied to organizations that do not even rise to the level of a disclosure entity, but nonetheless would be misleading to exclude. Some common examples of related parties are some government-sponsored enterprises and organizations governed by representatives from each of the governments that created the organization, including the United States, wherein the federal government has agreed to ongoing or contingent financial support to accomplish shared objectives. Related entities generally do not include government contractors, government vendors, some non-profits, organizations created by treaty, or special interest groups–although they can in the right circumstances (see id. at 7 and 31-33).
However, there are also certain entities that would probably be consolidation or disclosure entities, but are expressly excluded from the government wide GPFFR: the Federal Reserve System and bailout entities (see Financial Report of the United States Government 2016, p. 227, available at https://fiscal.treasury.gov/files/re...FR-(Final).pdf). In particular, this includes entities like Freddie Mac and Fannie Mae (see id.). If the government obtains rights in another entity which would give them the sort of control that normally makes a disclosure entity, but gains those rights when it “guarantee[s] or pay[s] debt for a privately owned entity whose failure could have an adverse impact on the nation’s economy, commerce, national security, etc. . .” those rights don’t count for determining a reporting entity (id).
This means that in addition to consolidation and disclosure entities, the scope of Standard 56 stretches to any organization which it would be misleading to exclude but isn’t otherwise incorporated into their list of covered entities. Because of this, although there is not a exhaustive list of whose financial reporting is impacted by Standard 56, if you can think of an entity related to the government, it is a safe bet they count as a covered reporting entity. This can include publicly traded corporations with significant funding and/or control from the federal government.
C. Changes to Disclosure Standards Under Standard 56
For these covered entities, Standard 56 offers financial reporting exceptions in a few situations for national security purposes. These reporting exceptions are the meat of Standard 56, three rules substantially modifying the reporting requirements of the above discussed entities to varying degrees (see FASAB Statement of Federal Financial Accounting Standards 56, p. 6, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
In general, disclosure entities are required to provide their financial reporting in a manner which is clear, concise, meaningful, and transparent (see FASAB Statement of Federal Financial Accounting Standards 47, para 71-73, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf). This is done through a single, integrated report of finances disclosing the relationship of the organization to the government and related entities, the nature and magnitude of their activity and their financial balances, and a description of financial and non-financial risks, potential benefits, and, if possible, the amount of the federal government’s exposure to gains and losses from the past or future operations of the disclosure entity or entities (see id. at para 74). This generally includes how much control or influence over the entity is exercised, key terms in their contractual agreements, percentage ownership and voting rights, a summary of assets, liabilities, revenues, expenses, gains and losses, key financial indicators, information on how their reports are stored and can be obtained, and quite a bit more (see id.). Essentially what is required is a transparent summary of how money is spent to provide accountability to the public. Standard 56 creates three loopholes to this disclosure standard.
D. Modifications to Avoid Disclosure of Classified Information
The first new loophole allows disclosure entities to modify their financial reports to “prevent the disclosure of classified information in an unclassified GPFFR” so long as these modifications do not change the net results of operations and net position. (See FASAB Statement of Federal Financial Accounting Standards 56, p. 6, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
This ultimately means that, when done to conceal confidential information, entities can–and are essentially required to under the terms of Standard 56–shift money from one line item to another so long as the totals stay consistent. The rule also allows entities to omit the line item entirely while retaining the amounts so as to maintain the same net results. This means that readers of these reports will never know if the amounts reported spent on specific projects or things are an accurate representation (see id.). As you might expect given the rationale of this being a national security precaution, there will not be any narrative in these reports explaining or revealing where a modification has taken place (see id.). If they can maintain net position in their reports, an entity can even omit a project entirely by folding it into another department or project within the same entity.
While it could obviously be worse for transparency purposes, the alternative would be that the amounts would just be omitted entirely. That brings us to the next two changes to accounting standards created by Standard 56.
E. Reporting on Consolidation Entities
We briefly discussed consolidation entities above as one of the larger loopholes to reporting within Standard 56. This is because the second change to reporting requirements of Standard 56 allows the reporting entity which the consolidation entity is consolidated with to modify reports to avoid disclosure of confidential information even if that modification changes net results of operations or net position. The reporting entity can move the financials of the consolidation entity or even choose not to include it in its report; full stop. (See FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
The concept of consolidation entities being incorporated into the reports of a larger reporting entity is far from new. FASAB has memorandums detailing the rules regarding consolidation from as far back as 2012 (see FASAB Federal Reporting Entity Memorandum, November 29, 2012, available at http://files.fasab.gov/pdffiles/tab_...al_2012dec.pdf). By itself, it is not a particularly problematic issue. Under FASAB rules, consolidation in financial reporting is appropriate for those organizations financed by the taxpayer, governed by elected or appointed officials, imposing risks and rewards on the taxpayer, and providing goods and services on a non-market basis. However, consolidation is not appropriate for organizations operating with a high degree of autonomy (see id. at 7).
In general, where an organization is controlled by the federal government and stands to make or lose money, but doesn’t have enough independence for a disclosure entity, it is included somewhere as a consolidation entity (see FASAB Statement of Federal Financial Accounting Standards 47, pp. 14-15, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf). As you’ve seen, the determination of what sort of entity something is hinges a great deal on the level of autonomy of the entity–the greater the control the government has, the more likely something will be classified as a consolidation entity. This control doesn’t mean the government has to actively manage on the day-to-day, but does require an examination of–among other things–whether the government can do things like appoint a majority of board members, dissolve the organization, authorize or deny action within the organization on some or all issues, or direct the policies or use of assets within the organization, and/or direct investment decisions. Consolidation entities are only assigned to one component entity and, in general, where that sort of control exists for a consolidated entity, the public would rely on the larger reporting entity for information on the consolidation entity’s financials (see id.). Under the second accounting standard change within Standard 56, the public can’t even count on these financials being reported in the first place (see FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7).
F. Interpretations Modifying Reporting Standards in the Future
The final change to accounting standards within Standard 56 doesn’t do much at the moment, but has the greatest potential to undermine financial transparency in the future. It allows FASAB to issue Interpretations of Standard 56 in the future which would allow other modifications to financial reports for the purpose of avoiding disclosure of classified information. FASAB can, and likely will, release these Interpretations over time. These Interpretations can allow modifications to reporting without regard for maintaining an entity’s net results or net position in their reporting. Those interpretations may even be classified themselves (Appendix A, A16), resulting in a portion of the federal government’s accountability standards being concealed from the public (see FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7).
Looked at in the most optimistic light, this will allow FASAB to ensure that Standard 56 isn’t abused and issue rulings of when disclosure is necessary in situations not yet considered. Looked at in a less optimistic light, this means that the ability of the government to obfuscate financial records will continue to grow in the coming months and years, without public oversight, as Interpretations add to or clarify these existing loopholes.
IV. Administrative History of Statement 56
Statement 56, and its reporting exceptions, have been in the works within FASAB for months. When an issue is identified, FASAB performs preliminary deliberations, prepares the initial documents, and then releases a review version to the public for comment and public hearings. After the comment period, FASAB enters further deliberations to consider the comments and make revisions. Then, the Board approves the proposed statement by a two-thirds majority vote, and submits it to the principals (the OMB and the GAO) for review. If neither principal objects to the proposal after 90 days, it is published by FASAB and is added to the GAAP for federal entities (Definition: FASAB (Federal Accounting Standards Advisory Board), available at https://searchcompliance.techtarget....Advisory-Board).
For Standard 56, the exposure draft was published on July 12, 2018, with comments due by August 13, 2018. Seventeen comments were submitted by various departments, agencies, and accounting firms (see FASAB Classified Activities, available at http://fasab.gov/ca/). The final Statement 56 was published on October 4, 2018, with little if any change from the exposure draft. However, the comments on Statement 56 are themselves interesting and somewhat enlightening.
A. Commentary on Required Disclaimers
FASAB proposed two possible alternatives for disclosure/disclaimer requirements under Standard 56. Either reporting entities could be given a choice in whether or not to consistently disclose that certain presentations may have been modified, or all reporting entities must disclose the possibility that certain presentations may have been modified, regardless of actual modification (see FASAB Exposure Draft Interpretation of Federal Financial Accounting Standards 56: Classified Activities, available at https://fas.org/sgp/news/2018/07/fasab-review.pdf).
The SEC gave a fairly entertaining comment on Standard 56. After answering “No Comment” to literally every preceding question, the SEC gave its thoughts on FASAB’s proposal for how component entities should disclose that they have modified their reports. The SEC, the nation’s foremost agency in the fight against financial fraud, doesn’t think that every component entity should have to disclose that modifications may have occurred, and especially the SEC shouldn’t have to. The reasoning the SEC gave for this position was that they “believe that this would be misleading and likely to cause confusion for financial statement readers, by implying that SEC is involved in classified activities. It’s likely that SEC, as well as other agencies, would receive numerous inquiries from the public and from the media by including such an unexpected disclaimer in its financial statements.” In other words, they’re worried it would look strange to the public if they disclosed that they had modified their financial reporting, despite no such modification. The public may think it odd that component entities such as the SEC would make such a, in their own words, “unexpected disclaimer” (FASAB Exposure Draft: Classified Activities, SEC Comment, available at http://files.fasab.gov/pdffiles/CA_13_SEC.PDF).
Veterans Affairs and the Association of Government Accountants had a similar stance, and while they commented on other aspects of Standard 56 as well, they joined the SEC in criticizing a mandatory disclaimer, and suggested disclaimers would only be appropriate when GPFFRs were actually modified (see FASAB Classified Activities, available at http://fasab.gov/ca/).
Several other commenting parties had a different take on the required disclaimers. For instance, the Department of Defense’s Office of The Chief Financial Officer and the Department of the Interior wanted agencies to have the option to give a disclaimer or not, irregardless of whether or not they made changes to classified information under the new standard (id.). The Department of Energy’s Office of The Chief Financial Officer even felt it would be appropriate to have no disclaimers whatsoever, even if GPFFRs were materially modified (id.).
B. Federal Commentary on Standard 56 Generally
Various government agencies commented on the “meat” of Standard 56, and most were in favor2 of FASAB’s proposals in general. For instance, Housing and Urban Development had fairly positive comments across the board, and deferred greatly to the need to classify information. The organization agreed with all of FASAB’s methodology and conclusions, and stated the new standards would strike a correct balance between protecting classified information and a commitment to open government.
However, oddly enough, the Department of Defense Office of the Inspector General was particularly concerned with the proposed Statement. They wrote “[t]his proposed guidance is a major shift in Federal accounting guidance and, in our view, the potential impact is so expansive that it represents another comprehensive basis of accounting” (FASAB Exposure Draft: Classified Activities, Department of Defense Office of the Inspector General Comment, available at http://files.fasab.gov/pdffiles/CA_8_DoD_OIG.PDF). They suggested already existing methods like redaction are sufficient to protect classified information, and stated the FASAB “should clarify whether this proposed standard, or subsequent Interpretations, could permit entities to record misstated amounts in the financial statements to mislead readers with the stated purpose of protecting classified information. We believe that no accounting guidance should allow this type of accounting entry” (id.).
Additionally, while not quite as critical as the Inspector General, the Treasury expressed concerns about the modification of net results of operations and net position.
C. Concerns From Accounting Firms
The accounting firm Kearney & Company had a more critical take on the proposed standard as well. They worried that “[t]he FASAB’s proposed approach could result in material omissions in GPFFR. . . If GPFFR can be modified so material activity is no longer accurately presented to the reader of financial statements, its usefulness to public users is limited and subject to misinterpretation” (FASAB Exposure Draft: Classified Activities, Kearney & Company Comment, available at: http://files.fasab.gov/pdffiles/CA_14_Kearney_&_CO_.PDF).
The accounting firm KPMG was more concerned with clarity and consistency, stating that because of potential classified interpretations, only some people with clearance will be able to understand the complete set of GAAP. Because of this, “[i]t is not clear how management of each federal entity will be able to assert that their GPFFR have been prepared in accordance with GAAP when management does not have access to all of GAAP” (FASAB Exposure Draft: Classified Activities, KPMG Comment, available at http://files.fasab.gov/pdffiles/CA_2_KPMG.PDF).
V. The Results of Statement 56 for the Public
There is a legitimate existing tension between the need to protect confidential government information and the public’s interest in financial transparency and accountability. Standard 56 isn’t without possible justification. That being said, the concerns of both the accounting world and many within the federal government itself are extremely valid.
Statement 56 undercuts the reliability of government accounting standards and financial statements to such a degree as to render an already questionably valuable reporting tool virtually useless to the public. The possibility of false or omitted information renders the reports largely unreliable as to actual amounts, as does the fact that even an accurate report is rendered questionable by the very existence of modifications that are not necessarily exposed. Classifying portions of the federal GAAP mystifies the process even further, and the fuzzy definitions of reporting entities leaves the potential for this to touch not only direct government entities, but government contractors and other private (but federally entangled) entities. The general disclosure of the government–requiring all reporting entities to report the potential of modifications whether or not they actually exist in their report while simultaneously forbidding the actual disclosure of the actual existence of any modifications–is essentially a worst case in terms of transparency for the public.
VI. About Us
This article was written and edited by Michele Ferri and Jonathan Lurie of The Law Offices of Lurie and Ferri for use by The Solari Report. Michele Ferri and Jonathan Lurie are both practicing attorneys out of California. The Law Offices of Lurie and Ferri focus on working with start-up businesses as well as on intellectual property and business law issues. They can be found at http://www.lflawoffices.com/ or contacted at [email protected].
Sources
- FASAB
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1 The extent of what qualifies as classified or confidential information is determined by Executive Order 13526 (the most recent standard set back in 2009), changes over time, and could fill a book by itself. (https://www.archives.gov/isoo/policy...s/cnsi-eo.html).
2 The Departments of Veterans Affairs, Housing and Urban Development, Energy, and The Interior, all had agreement with the proposed standard more or less across the board, with a few exceptions for disagreements about the disclaimers.
6 COMMENTS
- https://secure.gravatar.com/avatar/3...?s=50&d=mm&r=gKevine Riner says:
JANUARY 15, 2019 AT 3:55 AM
Can I share this article? I put the title and source on FB and my friends reacted to the story.
REPLY - https://secure.gravatar.com/avatar/3...?s=50&d=mm&r=gKevine Riner says:
JANUARY 15, 2019 AT 4:05 AM
I wish it was possible to share this excellent article with my friends online so they can better understand what a can of worms our government is today. Especially at this time in history when anything embarrassing to or corruptions within agencies is deemed classified.
REPLY- https://secure.gravatar.com/avatar/4...?s=50&d=mm&r=gCatherine Fitts says:
JANUARY 28, 2019 AT 5:19 AM
This article is public. Please feel free to share with anyone you like. We try to make pieces that we write or commission that impact our most important policy issues open to the public.
- https://secure.gravatar.com/avatar/4...?s=50&d=mm&r=gCatherine Fitts says:
- #6,650
- Jun 2, 2019 8:26am Jun 2, 2019 8:26am
- | Commercial User | Joined Dec 2014 | 14,164 Posts
Inserted Video
- #6,651
- Jun 2, 2019 8:30am Jun 2, 2019 8:30am
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https://www.zerohedge.com/news/2019-...ops+to+zero%29
"It's all a fraud" tweeted Nunes, replying to a tweet by @JohnWHuber (Undercover Huber), who also posted a comparison between the Mueller report and a newly released transcript of a November 2017 voicemail message left by former Trump lawyer John Dowd, in which he asked former national security adviser Michael Flynn's attorney for a "heads up" if Flynn was planning on saying anything that might damage the president.
Mueller's team omitted key context suggesting that Dowd was trying to strongarm Flynn and possibly obstruct justice by shaping witness testimony, while the actual voicemail reveals that Dowd was careful not to tread into obstruction territory in what was a friendly and routine call between lawyers.
Dowd qualifies his request by saying "without you having to give up any...confidential information" in order to determine "If, on the other hand, we have, there's information that...implicates the President, then we've got a national security issue, or maybe a national security issue, I don't know... some issue, we got to-we got to deal with, not only for the President but for the country."
Mueller's deceptive edits beg the question; what else may have been manipulated by the special counsel to make Trump look guilty? When reached for comment by attorney 'Techno Fog' (@Techno_Fog), Dowd said of the edits: "It is unfair and despicable. It was a friendly privileged call between counsel - with NO conflict. I think Flynn got screwed."
We got a statement from former Trump lawyer John Dowd, responding to the Special Counsel's deceptive edits of his voicemail to Flynn's lawyer
"It is unfair and despicable. It was a friendly privileged call between counsel - with NO conflict. I think Flynn got screwed"
Dowd told Fox News: "During the joint defense relationship, counsel for the president provided to Flynn’s counsel documents, advice and encouragement to provide to SC [the special counsel] as part of his effort to cooperate with the SC," adding "SC never raised or questioned the president’s counsel about these allegations despite numerous opportunities to do so."
Flynn pleaded guilty last year to lying to the FBI about contacts with Russians and is currently awaiting sentencing.
DOJ stonewalls on Flynn evidence
Meanwhile, the Justice Department has resisted a court order to release the transcripts of Flynn's conversations with Russian officials, including former Russian ambassador Sergey Kislyak.
This raises at least two questions. First, did the DOJ give Flynn the transcripts? And second, did the DOJ violate a previous court order from Judge Emmett Sullivan to produce evidence during discovery?
· May 31, 2019
Replying to @Techno_Fog
Note - per competing Orders, still not certain if Judge Sullivan will require all audio recording transcripts be filed with court. DOJ seems to read the orders that he doesn't need them.https://twitter.com/Techno_Fog/status/1129416066382336000 …
Techno Fog@Techno_Fog
New entry from Judge Sullivan on the Flynn case.
Read closely at the dates and omissions - could be a change to his prior order that the gov't file "the transcripts of any other audio recordings of Mr. Flynn"
Dowd qualifies his request by saying "without you having to give up any...confidential information" in order to determine "If, on the other hand, we have, there's information that...implicates the President, then we've got a national security issue, or maybe a national security issue, I don't know... some issue, we got to-we got to deal with, not only for the President but for the country."
"It's all a fraud" tweeted Nunes, replying to a tweet by @JohnWHuber (Undercover Huber), who also posted a comparison between the Mueller report and a newly released transcript of a November 2017 voicemail message left by former Trump lawyer John Dowd, in which he asked former national security adviser Michael Flynn's attorney for a "heads up" if Flynn was planning on saying anything that might damage the president.
Mueller's team omitted key context suggesting that Dowd was trying to strongarm Flynn and possibly obstruct justice by shaping witness testimony, while the actual voicemail reveals that Dowd was careful not to tread into obstruction territory in what was a friendly and routine call between lawyers.
Dowd qualifies his request by saying "without you having to give up any...confidential information" in order to determine "If, on the other hand, we have, there's information that...implicates the President, then we've got a national security issue, or maybe a national security issue, I don't know... some issue, we got to-we got to deal with, not only for the President but for the country."
Once again #MuellerReport edited messages to make them appear more damaging, full transcript of this phone call reveals Dowd’s message was pretty typical for a lawyer and he clearly states he’s not interested in any confidential info. What else did they manipulate
https://abs.twimg.com/emoji/v2/72x72/1f644.png
Mueller's deceptive edits beg the question; what else may have been manipulated by the special counsel to make Trump look guilty? When reached for comment by attorney 'Techno Fog' (@Techno_Fog), Dowd said of the edits: "It is unfair and despicable. It was a friendly privileged call between counsel - with NO conflict. I think Flynn got screwed."
EXCLUSIVE
We got a statement from former Trump lawyer John Dowd, responding to the Special Counsel's deceptive edits of his voicemail to Flynn's lawyer
"It is unfair and despicable. It was a friendly privileged call between counsel - with NO conflict. I think Flynn got screwed"
Dowd told Fox News: "During the joint defense relationship, counsel for the president provided to Flynn’s counsel documents, advice and encouragement to provide to SC [the special counsel] as part of his effort to cooperate with the SC," adding "SC never raised or questioned the president’s counsel about these allegations despite numerous opportunities to do so."
Flynn pleaded guilty last year to lying to the FBI about contacts with Russians and is currently awaiting sentencing.
DOJ stonewalls on Flynn evidence
Meanwhile, the Justice Department has resisted a court order to release the transcripts of Flynn's conversations with Russian officials, including former Russian ambassador Sergey Kislyak.
This raises at least two questions. First, did the DOJ give Flynn the transcripts? And second, did the DOJ violate a previous court order from Judge Emmett Sullivan to produce evidence during discovery?
https://pbs.twimg.com/profile_images...9G9_normal.jpgTechno Fog@Techno_Fog
· May 31, 2019
Replying to @Techno_Fog
Note - per competing Orders, still not certain if Judge Sullivan will require all audio recording transcripts be filed with court. DOJ seems to read the orders that he doesn't need them.https://twitter.com/Techno_Fog/status/1129416066382336000 …
Techno Fog@Techno_Fog
New entry from Judge Sullivan on the Flynn case.
Read closely at the dates and omissions - could be a change to his prior order that the gov't file "the transcripts of any other audio recordings of Mr. Flynn"
Dowd qualifies his request by saying "without you having to give up any...confidential information" in order to determine "If, on the other hand, we have, there's information that...implicates the President, then we've got a national security issue, or maybe a national security issue, I don't know... some issue, we got to-we got to deal with, not only for the President but for the country."
- #6,653
- Jun 2, 2019 11:34am Jun 2, 2019 11:34am
- | Commercial User | Joined Dec 2014 | 14,164 Posts
http://www.whatdoesitmean.com/index2885.htm
June 2, 2019
Hillary Clinton Wins “Prison Lottery” To Keep America And China From Going To War
By: Sorcha Faal, and as reported to her Western Subscribers
A remarkable analysis contained in a new Foreign Intelligence Service (SVR) report circulating in the Kremlin today says that former US Secretary of State Hillary Clinton appears to be the winner of the “Prison Lottery” discussions currently ongoing in the US Department of Justice as to which Obama Regime officials are to be criminally charged and put on trial—a fact supported by President Donald Trump attorney Rudy Giuliani who just revealed that 3 to 5 top Obama officials are going to be indicted—and US Attorney General William Barr further revealing that the criminal investigation into Clinton is near completion—with it being most important to understand that as the trade confrontation between America and China is quickly spiraling towards war, the Chinese are yet to be convinced that Trump is in full control of his nation and are therefore hesitant to make any deal with him—most particularly due to the “Obama Shadow Government” doing everything in its power to defeat Trump’s foreign policy. [Note: Some words and/or phrases appearing in quotes in this report are English language approximations of Russian words/phrases having no exact counterpart.]
According to this report, from the very moment he took power, President Trump embarked on a course to correct the massive trade imbalance between the United States and China—an imbalance that climbed to its highest level on record in 2017—but that, in early April-2019, saw an “epic” trade deal being reached between Trump and the Chinese—with only the signing ceremony left to done.
Within a fortnight of Trump reaching this historic trade deal with China, however, this report notes, Special Counsel Robert Mueller released his findings on the Trump-Russia collusion investigation—and even though finding that no criminal conspiracy existed between Trump and Russia, along with Attorney General Barr determining there was no Trump obstruction, saw a diplomatic cable from Beijing being sent to Washington D.C. with systematic edits to a nearly 150-page draft trade agreement that blew up months of negotiations between the world’s two largest economies.
Upon China blowing up this historic trade deal, this report continues, President Trump correctly assessed that they did so because of their belief they could reach a deal more favorable to them with his Democrat Party opponents who might soon defeat him—and was a message being spread to the Chinese by the “Obama Shadow Government” who had begun secretly negotiating with Iran, too—and is being led by former President Barack Obama who’s been circling the globe these past weeks trashing Trump and America every chance he gets—the latest example being this past Friday when Obama trashed the United States during a speech in Brazil, and didn’t even know the difference between the US Constitution and Declaration of Independence.
President Trump, of course, this report details, quickly retaliated against China for blowing up this trade deal by slamming them with punishing new tariffs—that struck a Chinese economy already in freefall and yet to see the bottom it will soon hit—the full anger about of which was put on display before a delegation of American business leaders who, while in China this past week, were harangued for almost an hour by a member of the Chinese Politburo who described the US-China relationship as a “clash of civilizations” and boasted that China’s government-controlled system was far superior to the “Mediterranean Culture” of the West, with its internal divisions and aggressive foreign policy.
Coinciding with President Trump slamming China with these punishing tariffs that now endanger their entire economy, this report continues, he further began flooding the Pacific Ocean region around China with tens-of-thousands of American military forces—a massive military buildup now completed as evidenced by acting US Defense Secretary Patrick Shanahan blasting China yesterday and vowing “the United States will no longer 'tiptoe' around Chinese behavior in Asia”—a vow met near immediately by China who fired back and warned “the US side should not underestimate China’s determination and ability to safeguard its national sovereignty and territorial integrity”.
With this current volatile situation heading towards war it’s, perhaps, best summarized in the Los Angeles Times headline yesterday “For The U.S. and China, It’s Not A Trade War Anymore — It’s Something Worse”, this report concludes, left to President Trump before everything spirals out of control is his displaying to the Chinese that he, and he alone, is in full control of his country, not the “Obama Shadow Government”—and whose fastest and most effective means to do so is his criminally charging top Obama Regime officials—the most likely of whom will be Hillary Clinton—not just because of the many crimes she’s committed, but because she’s universally loathed by all political factions in America, both left and right—the best evidence of which is being displayed in the just opened play on Broadway in New York City titled “Hillary and Clinton”—that sees famous American actor John Lithgow playing the part of Bill Clinton, while the famous American actress Laurie Metcalf plays Hillary—and in the exchange that got the loudest audience cheers, saw Bill explaining to his wife Hillary why she lost the presidency: “People don’t like people who make them feel like shit”.
June 2, 2019
EU and US all rights reserved. Permission to use this report in its entirety is granted under the condition it is linked back to its original source at WhatDoesItMean.Com. Freebase content licensed under CC-BY and GFDL.
[Note: Many governments and their intelligence services actively campaign against the information found in these reports so as not to alarm their citizens about the many catastrophic Earth changes and events to come, a stance that the Sisters of Sorcha Faal strongly disagree with in believing that it is every human being’s right to know the truth. Due to our mission’s conflicts with that of those governments, the responses of their ‘agents’ has been a longstanding misinformation/misdirection campaign designed to discredit us, and others like us, that is exampled in numerous places, including HERE.]
[Note: The WhatDoesItMean.com website was created for and donated to the Sisters of Sorcha Faal in 2003 by a small group of American computer experts led by the late global technology guru Wayne Green(1922-2013) to counter the propaganda being used by the West to promote their illegal 2003 invasion of Iraq.]
[Note: The word Kremlin (fortress inside a city) as used in this report refers to Russian citadels, including in Moscow, having cathedrals wherein female Schema monks (Orthodox nuns) reside, many of whom are devoted to the mission of the Sisters of Sorcha Faal.]
Trump Races Global Nuclear War To Finish Line As World Holds Breath
The Epistle of Saint Helena: The Most Feared Book Of The Bible That Ignited World War II
America Is Tearing Itself Apart Because Of Two HistoriansThey Don’t Even Know The Names Of
Return To Main Page
June 2, 2019
Hillary Clinton Wins “Prison Lottery” To Keep America And China From Going To War
By: Sorcha Faal, and as reported to her Western Subscribers
A remarkable analysis contained in a new Foreign Intelligence Service (SVR) report circulating in the Kremlin today says that former US Secretary of State Hillary Clinton appears to be the winner of the “Prison Lottery” discussions currently ongoing in the US Department of Justice as to which Obama Regime officials are to be criminally charged and put on trial—a fact supported by President Donald Trump attorney Rudy Giuliani who just revealed that 3 to 5 top Obama officials are going to be indicted—and US Attorney General William Barr further revealing that the criminal investigation into Clinton is near completion—with it being most important to understand that as the trade confrontation between America and China is quickly spiraling towards war, the Chinese are yet to be convinced that Trump is in full control of his nation and are therefore hesitant to make any deal with him—most particularly due to the “Obama Shadow Government” doing everything in its power to defeat Trump’s foreign policy. [Note: Some words and/or phrases appearing in quotes in this report are English language approximations of Russian words/phrases having no exact counterpart.]
http://www.whatdoesitmean.com/lock1.jpg
According to this report, from the very moment he took power, President Trump embarked on a course to correct the massive trade imbalance between the United States and China—an imbalance that climbed to its highest level on record in 2017—but that, in early April-2019, saw an “epic” trade deal being reached between Trump and the Chinese—with only the signing ceremony left to done.
Within a fortnight of Trump reaching this historic trade deal with China, however, this report notes, Special Counsel Robert Mueller released his findings on the Trump-Russia collusion investigation—and even though finding that no criminal conspiracy existed between Trump and Russia, along with Attorney General Barr determining there was no Trump obstruction, saw a diplomatic cable from Beijing being sent to Washington D.C. with systematic edits to a nearly 150-page draft trade agreement that blew up months of negotiations between the world’s two largest economies.
http://www.whatdoesitmean.com/lock2.jpg
Upon China blowing up this historic trade deal, this report continues, President Trump correctly assessed that they did so because of their belief they could reach a deal more favorable to them with his Democrat Party opponents who might soon defeat him—and was a message being spread to the Chinese by the “Obama Shadow Government” who had begun secretly negotiating with Iran, too—and is being led by former President Barack Obama who’s been circling the globe these past weeks trashing Trump and America every chance he gets—the latest example being this past Friday when Obama trashed the United States during a speech in Brazil, and didn’t even know the difference between the US Constitution and Declaration of Independence.
http://www.whatdoesitmean.com/lock3.jpg
Former President Barack Obama circles globe trashing President Trump and America every chance he gets
President Trump, of course, this report details, quickly retaliated against China for blowing up this trade deal by slamming them with punishing new tariffs—that struck a Chinese economy already in freefall and yet to see the bottom it will soon hit—the full anger about of which was put on display before a delegation of American business leaders who, while in China this past week, were harangued for almost an hour by a member of the Chinese Politburo who described the US-China relationship as a “clash of civilizations” and boasted that China’s government-controlled system was far superior to the “Mediterranean Culture” of the West, with its internal divisions and aggressive foreign policy.
Coinciding with President Trump slamming China with these punishing tariffs that now endanger their entire economy, this report continues, he further began flooding the Pacific Ocean region around China with tens-of-thousands of American military forces—a massive military buildup now completed as evidenced by acting US Defense Secretary Patrick Shanahan blasting China yesterday and vowing “the United States will no longer 'tiptoe' around Chinese behavior in Asia”—a vow met near immediately by China who fired back and warned “the US side should not underestimate China’s determination and ability to safeguard its national sovereignty and territorial integrity”.
http://www.whatdoesitmean.com/lock4.jpg
With this current volatile situation heading towards war it’s, perhaps, best summarized in the Los Angeles Times headline yesterday “For The U.S. and China, It’s Not A Trade War Anymore — It’s Something Worse”, this report concludes, left to President Trump before everything spirals out of control is his displaying to the Chinese that he, and he alone, is in full control of his country, not the “Obama Shadow Government”—and whose fastest and most effective means to do so is his criminally charging top Obama Regime officials—the most likely of whom will be Hillary Clinton—not just because of the many crimes she’s committed, but because she’s universally loathed by all political factions in America, both left and right—the best evidence of which is being displayed in the just opened play on Broadway in New York City titled “Hillary and Clinton”—that sees famous American actor John Lithgow playing the part of Bill Clinton, while the famous American actress Laurie Metcalf plays Hillary—and in the exchange that got the loudest audience cheers, saw Bill explaining to his wife Hillary why she lost the presidency: “People don’t like people who make them feel like shit”.
http://www.whatdoesitmean.com/lock5.jpg
June 2, 2019
[Note: Many governments and their intelligence services actively campaign against the information found in these reports so as not to alarm their citizens about the many catastrophic Earth changes and events to come, a stance that the Sisters of Sorcha Faal strongly disagree with in believing that it is every human being’s right to know the truth. Due to our mission’s conflicts with that of those governments, the responses of their ‘agents’ has been a longstanding misinformation/misdirection campaign designed to discredit us, and others like us, that is exampled in numerous places, including HERE.]
[Note: The WhatDoesItMean.com website was created for and donated to the Sisters of Sorcha Faal in 2003 by a small group of American computer experts led by the late global technology guru Wayne Green(1922-2013) to counter the propaganda being used by the West to promote their illegal 2003 invasion of Iraq.]
[Note: The word Kremlin (fortress inside a city) as used in this report refers to Russian citadels, including in Moscow, having cathedrals wherein female Schema monks (Orthodox nuns) reside, many of whom are devoted to the mission of the Sisters of Sorcha Faal.]
Trump Races Global Nuclear War To Finish Line As World Holds Breath
The Epistle of Saint Helena: The Most Feared Book Of The Bible That Ignited World War II
America Is Tearing Itself Apart Because Of Two HistoriansThey Don’t Even Know The Names Of
Return To Main Page
- #6,654
- Jun 2, 2019 2:57pm Jun 2, 2019 2:57pm
- | Commercial User | Joined Dec 2014 | 14,164 Posts
Inserted Video
- #6,655
- Jun 2, 2019 8:02pm Jun 2, 2019 8:02pm
- | Commercial User | Joined Dec 2014 | 14,164 Posts
https://www.oftwominds.com/blog.html
Why Being a Politician Is No Longer Fun
May 31, 2019
As a society, we are ill-prepared for the end of "politics is the solution."
It's fun to be a politician when there's plenty of tax revenues and borrowed money to distribute, and when the goodies get bipartisan support. An economy that's expanding all household incomes more or less equally is fun, fun, fun for politicians because more household income generates more income tax revenues and more spending that generates other taxes.
Despite the usual ideological squabbles, the general mood is upbeat: the horse-trading is about the relative share of the spoils each constituency will receive. Nobody gets everything they want, but everybody gets a good chunk and after an appropriate period of whining, resentment and indignation eventually counts their blessings.
But once the pie starts shrinking, the mood darkens: rather than goodies being distributed, losses and belt-tightening must be distributed. The game is now zero-sum: one constituency's gain is another's dead loss.
Politics is no longer fun once the pie starts shrinking. The illusion of "growth" can be maintained for a while by borrowing enormous sums and distributing the windfall as if it were real, organic growth but eventually the wheels fall off the substitute debt for income and tax revenues game and the entire rotten structure collapses.
The other dynamic in play that's visible in the chart below is the distribution of wealth and power is so asymmetric that it's destroying politics as a "solution." Financialization, neoliberalism and its handmaiden globalization have skewed income, wealth and power to the very top of the distribution pyramid: the rich are getting richer, and the super-rich are getting super-richer--and more politically powerful as a result.
But the asymmetry isn't driven solely by the perversities of neoliberalism / financialization: beneath the surface, the economy is shifting in fundamentally dramatic ways that exacerbate wealth-income distribution asymmetries: there are fewer winners and more losers.
These forces have polarized politics into two camps: one with an ideological faith that markets left to themselves will sort it all out to everyone's satisfaction and the other camp with an ideological faith that the central state is the only solution via redistribution of income.
As I've explained here many times and in my many books, both are wrong:neither the market nor the state can maintain the status quo in an era of DeGrowth and tectonic shifts in demographics, natural resources, energy, technology, etc.
Humans being humans, the failure of politics as a "solution" only hardens the ideological resolve of each camp, insuring even more bitter partisanship and more zealotry, as neither side is willing to admit that both "solutions" are wanting, as both "solutions" only work in periods of rapid growth that generates more goodies for everyone.
That era ended a decade ago, and the illusion of growth has been generated by the temporary artifice of debt and money-creation.
As a society, we are ill-prepared for the end of "politics is the solution." No wonder being a politician is no longer fun.
https://www.oftwominds.com/photos201...uality4-19.jpg
Pathfinding our Destiny: Preventing the Final Fall of Our Democratic Republic ($6.95 ebook, $12 print, $13.08 audiobook): Read the first section for free in PDF format.
My new mystery The Adventures of the Consulting Philosopher: The Disappearance of Drake is a ridiculously affordable $1.29 (Kindle) or $8.95 (print); read the first chapters for free (PDF)
My book Money and Work Unchained is now $6.95 for the Kindle ebook and $15 for the print edition. Read the first section for free in PDF format.
If you found value in this content, please join me in seeking solutions by becoming a $1/month patron of my work via patreon.com. New benefit for subscribers/patrons: a monthly Q&A where I respond to your questions/topics.
Why Being a Politician Is No Longer Fun
May 31, 2019
As a society, we are ill-prepared for the end of "politics is the solution."
It's fun to be a politician when there's plenty of tax revenues and borrowed money to distribute, and when the goodies get bipartisan support. An economy that's expanding all household incomes more or less equally is fun, fun, fun for politicians because more household income generates more income tax revenues and more spending that generates other taxes.
Despite the usual ideological squabbles, the general mood is upbeat: the horse-trading is about the relative share of the spoils each constituency will receive. Nobody gets everything they want, but everybody gets a good chunk and after an appropriate period of whining, resentment and indignation eventually counts their blessings.
But once the pie starts shrinking, the mood darkens: rather than goodies being distributed, losses and belt-tightening must be distributed. The game is now zero-sum: one constituency's gain is another's dead loss.
Politics is no longer fun once the pie starts shrinking. The illusion of "growth" can be maintained for a while by borrowing enormous sums and distributing the windfall as if it were real, organic growth but eventually the wheels fall off the substitute debt for income and tax revenues game and the entire rotten structure collapses.
The other dynamic in play that's visible in the chart below is the distribution of wealth and power is so asymmetric that it's destroying politics as a "solution." Financialization, neoliberalism and its handmaiden globalization have skewed income, wealth and power to the very top of the distribution pyramid: the rich are getting richer, and the super-rich are getting super-richer--and more politically powerful as a result.
But the asymmetry isn't driven solely by the perversities of neoliberalism / financialization: beneath the surface, the economy is shifting in fundamentally dramatic ways that exacerbate wealth-income distribution asymmetries: there are fewer winners and more losers.
These forces have polarized politics into two camps: one with an ideological faith that markets left to themselves will sort it all out to everyone's satisfaction and the other camp with an ideological faith that the central state is the only solution via redistribution of income.
As I've explained here many times and in my many books, both are wrong:neither the market nor the state can maintain the status quo in an era of DeGrowth and tectonic shifts in demographics, natural resources, energy, technology, etc.
Humans being humans, the failure of politics as a "solution" only hardens the ideological resolve of each camp, insuring even more bitter partisanship and more zealotry, as neither side is willing to admit that both "solutions" are wanting, as both "solutions" only work in periods of rapid growth that generates more goodies for everyone.
That era ended a decade ago, and the illusion of growth has been generated by the temporary artifice of debt and money-creation.
As a society, we are ill-prepared for the end of "politics is the solution." No wonder being a politician is no longer fun.
https://www.oftwominds.com/photos201...uality4-19.jpg
Pathfinding our Destiny: Preventing the Final Fall of Our Democratic Republic ($6.95 ebook, $12 print, $13.08 audiobook): Read the first section for free in PDF format.
My new mystery The Adventures of the Consulting Philosopher: The Disappearance of Drake is a ridiculously affordable $1.29 (Kindle) or $8.95 (print); read the first chapters for free (PDF)
My book Money and Work Unchained is now $6.95 for the Kindle ebook and $15 for the print edition. Read the first section for free in PDF format.
If you found value in this content, please join me in seeking solutions by becoming a $1/month patron of my work via patreon.com. New benefit for subscribers/patrons: a monthly Q&A where I respond to your questions/topics.
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- Jun 2, 2019 8:38pm Jun 2, 2019 8:38pm
- | Commercial User | Joined Dec 2014 | 14,164 Posts
Inserted Video
- #6,657
- Jun 2, 2019 9:10pm Jun 2, 2019 9:10pm
- | Commercial User | Joined Dec 2014 | 14,164 Posts
https://constitution.solari.com/fasa...IZGqYLzK4SyIqI
FASAB Statement 56: Understanding New Government Financial Accounting Loopholes
January 10, 2019 Solari Staff Articles 13
https://constitution.solari.com/wp-c...-1030x438.jpeg
Table of Contents
I. Introduction
II. History of the Federal Accounting Standards Advisory Board (FASAB)
III. FASAB and Standard 56
A. What Does Standard 56 Do?
B. Reporting Entities Within the Scope of Standard 56
C. Changes to Disclosure Standards Under Standard 56
D. Modifications to Avoid Disclosure of Classified Information
E. Reporting on Consolidation Entities
F. Interpretations Modifying Reporting Standards in the Future
IV. Administrative History of Statement 56
A. Commentary on Required Disclaimers
B. Federal Commentary on Standard 56 Generally
C. Concerns From Accounting Firms
V. The Results of Statement 56 for the Public
VI. About Us
December 29, 2018
I. Introduction
Financial accountability for the government is a cornerstone of a functioning representative democracy. The ability for the people to know where taxpayer money goes to is crucial to having an informed opinion regarding the actions of your representatives and to react accordingly. Unfortunately, as we’ve discussed in previous articles, the current state of government accounting is far from ideal–often bordering on useless to the public. This is largely due to lax enforcement of existing laws such as the Chief Financial Officers (CFO) Act, but also stems from the very real tension between completely transparent government financial disclosure and national security interests (see The U.S. Statutes Creating Modern Constitutional Financial Management and Reporting Requirements and the Government’s Failure to Follow Them, available at https://constitution.solari.com/the-...o-follow-them/). As of the last few months, this tension has taken the future of government financial disclosure to the public to new levels of opacity. The Federal Accounting Standards Advisory Board (FASAB) has released Statement of Federal Financial Accounting Standards 56 (Standard 56), taking government accounting practices from laxly enforced reporting standards to a new benchmark entirely–expressly approved obfuscation of reporting and, in some cases, outright concealing financials.
This sounds fairly alarmist at first blush but, simply put, Standard 56 creates a set of situations where government entities may move numbers around to conceal where money is actually spent or even not report spending outright. Many of the concepts in Standard 56 are not new and have been discussed in FASAB reports for nearly a decade. However, these new changes make a substantial portion of government financial reporting so unreliable as to not be a useful tool to the public (see FASAB Statement of Federal Financial Accounting Standards 56, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
In order to fully understand Standard 56, we will be taking a fairly deep dive on the new accounting standards it creates—from the history leading up to the new rules, to summarizing the exact changes of Standard 56. We’ve said that Standard 56 isn’t new, and this is true; it has hundreds and hundreds of pages of memorandums and the like which came before it, outlining the exact parameters of these new reporting rules. For that reason, a complete summary of what a government entity must report will not be possible–or likely even useful–in an article of this length. That being said, we will explore the role of FASAB itself, the functional changes of Standard 56, and how it will impact the ability of the U.S. taxpayer to see how their money is spent.
II. History of the Federal Accounting Standards Advisory Board (FASAB)
FASAB came about as a response to the requirements of the CFO Act. We previously wrote about the CFO Act in The U.S. Statutes Creating Modern Constitutional Financial Management and Reporting Requirements and the Government’s Failure to Follow Them (available at https://constitution.solari.com/the-...o-follow-them/). Under the Act, the individual CFOs of covered federal agencies are responsible for preparing financial statements for regular audit in order to ensure accuracy in accounting. The CFOs also were tasked by the Act with integrating accounting and budget information into a form consistent with those used to make budgets, put together a uniform financial management system for their agency, and–perhaps most importantly–make sure that the system they put together allowed for actual useful measurement of the financial performance of the CFO’s agency.
However, the CFO Act was light on the details, and after the Act passed in 1990, there was a need to determine the actual details of the accounting standards required. Therefore, the Treasury, OMB, and Comptroller General signed a Memorandum jointly establishing the FASAB to “consider and recommend the appropriate accounting standards for the federal government” (see History of FASAB, available at http://www.fasab.gov/the-history-of-fasab/). Until 1999, FASAB simply gave recommendations to those three sponsoring entities. Then, in 1999, FASAB was approved to set final generally acceptable accounting practices (GAAP) for the federal government, with only a 90 day review period by the sponsoring entities. In 2002, the Treasury was removed as a sponsoring entity, leaving the OMB and GAO as the only entities able to object to FASAB set standards (see id.).
III. FASAB and Standard 56
As mentioned above, since 1999, FASAB sets the final GAAP for the federal government. These practices are then used throughout the federal government to determine the content and structure of the financial reports the CFO Act requires federal government agencies, departments, and the like to prepare. While the GAAP are not themselves literally binding law, they do show what the federal government considers to be compliance with the law. As long as an agency follows GAAP, there will generally be a presumption that it is also complying with the federal financial accounting requirements. Therefore, unless the underlying legislation is amended by Congress, FASAB essentially determines the extent of the federal government’s financial transparency (see id.). With the official adoption of Standard 56 as of October 4, 2018–completely unchanged from the pre-comment period version from July 2018–FASAB has determined that national security concerns essentially trump the need for financial transparency to the public. So how does Standard 56 do this?
A. What Does Standard 56 Do?
In the absolute most simple terms, Standard 56 allows federal entities to shift amounts from line item to line item and sometimes even omit spending altogether when reporting their financials in order to avoid the potential of revealing classified information.1 However, as with all laws, nearly every word in that sentence is a complicated concept to unpack. Who counts as a federal reporting entity? When and how can these entities conceal or remove financial information from their reports? What information can be removed? When does something count as confidential, and who makes that determination? All of these questions have enormous bodies of writing in FASAB memorandums addressing, and sometimes failing to address, their answers.
The simplest place to start with understanding Standard 56 is its scope. It applies to federal entities that issue unclassified general purpose federal financial reports (GPFFR), including where one entity is consolidated with another. This means it only applies to otherwise unclassified financial reports where there is a risk of revealing classified information; classified financial reports are their own can of worms. (See generally, FASAB Statement of Federal Financial Accounting Standards 56, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf). Standard 56 also doesn’t remove the actual requirement to report, it just allows these entities to change their reports in ways that don’t reflect their actual spending (see id.). However, for the purposes of government transparency, determining who is responsible for classifying information, and/or removing that information from unclassified reports, is quite opaque for the average interested citizen.
B. Reporting Entities Within the Scope of Standard 56
The actual reporting entities empowered by the standards of Standard 56 include organizations which are included in the government wide GPFFR (see id.). This includes any entities that are “(1) budgeted for by elected officials of the federal government, (2) owned by the federal government, or (3) controlled by the federal government with risk of loss or expectation of benefits” (FASAB Statement of Federal Financial Accounting Standards 47, p. 1, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf).
However, many different departments, bureaus, and agencies prepare their own GPFFRs as well. The various entities that both prepare their own GPFFR and are within a larger reporting entity are called Component Reporting Entities. This includes executive departments, independent agencies, government corporations, legislative agencies, and federal courts (id. at 7). Their GPFFRs are then consolidated into the government wide GPFFR.
Under the Component Reporting Entities and included in their GPFFRs are various other organizations, from smaller departments to government contractors, which are split into two categories: disclosure entities and consolidation entities (see id.).
Consolidation entities are entities like agencies and departments. A consolidation entity generally (1) is financed through taxes and other non-exchange revenues, (2) is governed by the Congress and/or the President, (3) imposes or may impose risks and rewards to the federal government, and (4) provides goods and services on a non-market basis (see id. at 16). For instance, a department or corporation established by Congress to perform a government function is a classic example of a consolidation entity. Consolidated entities are reported by a larger entity as part and parcel of their financial reporting–as if they were one economic entity. We will discuss this type of entity later in great depth, as it constitutes one of the largest potential loopholes of Standard 56 (see id.).
Disclosure entities are financially independent organizations. These organizations still need to be included in the government wide GPFFR, but do not fully meet the four characteristics of consolidated entities above. They include quasi-governmental entities, organizations in receiverships and conservatorships, and organizations owned or controlled through federal government intervention actions (see id. at 16). A good example would be government-established non-profits that have a significant portion of their board appointed by the President but are entirely funded by their own activities.
Additionally, there are “related parties,” which are organizations where at least one of the parties involved has the ability to exercise significant influence over the policy decisions of the other party. This significant influence does not need to amount to control, but can include things such as representation on a board of directors, participation in policy making procedures, shared managerial personnel, and things along those lines. The existence of significant influence is generally determined through a full analysis of the particulars of each situation. This classification is usually applied to organizations that do not even rise to the level of a disclosure entity, but nonetheless would be misleading to exclude. Some common examples of related parties are some government-sponsored enterprises and organizations governed by representatives from each of the governments that created the organization, including the United States, wherein the federal government has agreed to ongoing or contingent financial support to accomplish shared objectives. Related entities generally do not include government contractors, government vendors, some non-profits, organizations created by treaty, or special interest groups–although they can in the right circumstances (see id. at 7 and 31-33).
However, there are also certain entities that would probably be consolidation or disclosure entities, but are expressly excluded from the government wide GPFFR: the Federal Reserve System and bailout entities (see Financial Report of the United States Government 2016, p. 227, available at https://fiscal.treasury.gov/files/re...FR-(Final).pdf). In particular, this includes entities like Freddie Mac and Fannie Mae (see id.). If the government obtains rights in another entity which would give them the sort of control that normally makes a disclosure entity, but gains those rights when it “guarantee[s] or pay[s] debt for a privately owned entity whose failure could have an adverse impact on the nation’s economy, commerce, national security, etc. . .” those rights don’t count for determining a reporting entity (id).
This means that in addition to consolidation and disclosure entities, the scope of Standard 56 stretches to any organization which it would be misleading to exclude but isn’t otherwise incorporated into their list of covered entities. Because of this, although there is not a exhaustive list of whose financial reporting is impacted by Standard 56, if you can think of an entity related to the government, it is a safe bet they count as a covered reporting entity. This can include publicly traded corporations with significant funding and/or control from the federal government.
C. Changes to Disclosure Standards Under Standard 56
For these covered entities, Standard 56 offers financial reporting exceptions in a few situations for national security purposes. These reporting exceptions are the meat of Standard 56, three rules substantially modifying the reporting requirements of the above discussed entities to varying degrees (see FASAB Statement of Federal Financial Accounting Standards 56, p. 6, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
In general, disclosure entities are required to provide their financial reporting in a manner which is clear, concise, meaningful, and transparent (see FASAB Statement of Federal Financial Accounting Standards 47, para 71-73, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf). This is done through a single, integrated report of finances disclosing the relationship of the organization to the government and related entities, the nature and magnitude of their activity and their financial balances, and a description of financial and non-financial risks, potential benefits, and, if possible, the amount of the federal government’s exposure to gains and losses from the past or future operations of the disclosure entity or entities (see id. at para 74). This generally includes how much control or influence over the entity is exercised, key terms in their contractual agreements, percentage ownership and voting rights, a summary of assets, liabilities, revenues, expenses, gains and losses, key financial indicators, information on how their reports are stored and can be obtained, and quite a bit more (see id.). Essentially what is required is a transparent summary of how money is spent to provide accountability to the public. Standard 56 creates three loopholes to this disclosure standard.
D. Modifications to Avoid Disclosure of Classified Information
The first new loophole allows disclosure entities to modify their financial reports to “prevent the disclosure of classified information in an unclassified GPFFR” so long as these modifications do not change the net results of operations and net position. (See FASAB Statement of Federal Financial Accounting Standards 56, p. 6, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
This ultimately means that, when done to conceal confidential information, entities can–and are essentially required to under the terms of Standard 56–shift money from one line item to another so long as the totals stay consistent. The rule also allows entities to omit the line item entirely while retaining the amounts so as to maintain the same net results. This means that readers of these reports will never know if the amounts reported spent on specific projects or things are an accurate representation (see id.). As you might expect given the rationale of this being a national security precaution, there will not be any narrative in these reports explaining or revealing where a modification has taken place (see id.). If they can maintain net position in their reports, an entity can even omit a project entirely by folding it into another department or project within the same entity.
While it could obviously be worse for transparency purposes, the alternative would be that the amounts would just be omitted entirely. That brings us to the next two changes to accounting standards created by Standard 56.
E. Reporting on Consolidation Entities
We briefly discussed consolidation entities above as one of the larger loopholes to reporting within Standard 56. This is because the second change to reporting requirements of Standard 56 allows the reporting entity which the consolidation entity is consolidated with to modify reports to avoid disclosure of confidential information even if that modification changes net results of operations or net position. The reporting entity can move the financials of the consolidation entity or even choose not to include it in its report; full stop. (See FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
The concept of consolidation entities being incorporated into the reports of a larger reporting entity is far from new. FASAB has memorandums detailing the rules regarding consolidation from as far back as 2012 (see FASAB Federal Reporting Entity Memorandum, November 29, 2012, available at http://files.fasab.gov/pdffiles/tab_...al_2012dec.pdf). By itself, it is not a particularly problematic issue. Under FASAB rules, consolidation in financial reporting is appropriate for those organizations financed by the taxpayer, governed by elected or appointed officials, imposing risks and rewards on the taxpayer, and providing goods and services on a non-market basis. However, consolidation is not appropriate for organizations operating with a high degree of autonomy (see id. at 7).
In general, where an organization is controlled by the federal government and stands to make or lose money, but doesn’t have enough independence for a disclosure entity, it is included somewhere as a consolidation entity (see FASAB Statement of Federal Financial Accounting Standards 47, pp. 14-15, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf). As you’ve seen, the determination of what sort of entity something is hinges a great deal on the level of autonomy of the entity–the greater the control the government has, the more likely something will be classified as a consolidation entity. This control doesn’t mean the government has to actively manage on the day-to-day, but does require an examination of–among other things–whether the government can do things like appoint a majority of board members, dissolve the organization, authorize or deny action within the organization on some or all issues, or direct the policies or use of assets within the organization, and/or direct investment decisions. Consolidation entities are only assigned to one component entity and, in general, where that sort of control exists for a consolidated entity, the public would rely on the larger reporting entity for information on the consolidation entity’s financials (see id.). Under the second accounting standard change within Standard 56, the public can’t even count on these financials being reported in the first place (see FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7).
F. Interpretations Modifying Reporting Standards in the Future
The final change to accounting standards within Standard 56 doesn’t do much at the moment, but has the greatest potential to undermine financial transparency in the future. It allows FASAB to issue Interpretations of Standard 56 in the future which would allow other modifications to financial reports for the purpose of avoiding disclosure of classified information. FASAB can, and likely will, release these Interpretations over time. These Interpretations can allow modifications to reporting without regard for maintaining an entity’s net results or net position in their reporting. Those interpretations may even be classified themselves (Appendix A, A16), resulting in a portion of the federal government’s accountability standards being concealed from the public (see FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7).
Looked at in the most optimistic light, this will allow FASAB to ensure that Standard 56 isn’t abused and issue rulings of when disclosure is necessary in situations not yet considered. Looked at in a less optimistic light, this means that the ability of the government to obfuscate financial records will continue to grow in the coming months and years, without public oversight, as Interpretations add to or clarify these existing loopholes.
IV. Administrative History of Statement 56
Statement 56, and its reporting exceptions, have been in the works within FASAB for months. When an issue is identified, FASAB performs preliminary deliberations, prepares the initial documents, and then releases a review version to the public for comment and public hearings. After the comment period, FASAB enters further deliberations to consider the comments and make revisions. Then, the Board approves the proposed statement by a two-thirds majority vote, and submits it to the principals (the OMB and the GAO) for review. If neither principal objects to the proposal after 90 days, it is published by FASAB and is added to the GAAP for federal entities (Definition: FASAB (Federal Accounting Standards Advisory Board), available at https://searchcompliance.techtarget....Advisory-Board).
For Standard 56, the exposure draft was published on July 12, 2018, with comments due by August 13, 2018. Seventeen comments were submitted by various departments, agencies, and accounting firms (see FASAB Classified Activities, available at http://fasab.gov/ca/). The final Statement 56 was published on October 4, 2018, with little if any change from the exposure draft. However, the comments on Statement 56 are themselves interesting and somewhat enlightening.
A. Commentary on Required Disclaimers
FASAB proposed two possible alternatives for disclosure/disclaimer requirements under Standard 56. Either reporting entities could be given a choice in whether or not to consistently disclose that certain presentations may have been modified, or all reporting entities must disclose the possibility that certain presentations may have been modified, regardless of actual modification (see FASAB Exposure Draft Interpretation of Federal Financial Accounting Standards 56: Classified Activities, available at https://fas.org/sgp/news/2018/07/fasab-review.pdf).
The SEC gave a fairly entertaining comment on Standard 56. After answering “No Comment” to literally every preceding question, the SEC gave its thoughts on FASAB’s proposal for how component entities should disclose that they have modified their reports. The SEC, the nation’s foremost agency in the fight against financial fraud, doesn’t think that every component entity should have to disclose that modifications may have occurred, and especially the SEC shouldn’t have to. The reasoning the SEC gave for this position was that they “believe that this would be misleading and likely to cause confusion for financial statement readers, by implying that SEC is involved in classified activities. It’s likely that SEC, as well as other agencies, would receive numerous inquiries from the public and from the media by including such an unexpected disclaimer in its financial statements.” In other words, they’re worried it would look strange to the public if they disclosed that they had modified their financial reporting, despite no such modification. The public may think it odd that component entities such as the SEC would make such a, in their own words, “unexpected disclaimer” (FASAB Exposure Draft: Classified Activities, SEC Comment, available at http://files.fasab.gov/pdffiles/CA_13_SEC.PDF).
Veterans Affairs and the Association of Government Accountants had a similar stance, and while they commented on other aspects of Standard 56 as well, they joined the SEC in criticizing a mandatory disclaimer, and suggested disclaimers would only be appropriate when GPFFRs were actually modified (see FASAB Classified Activities, available at http://fasab.gov/ca/).
Several other commenting parties had a different take on the required disclaimers. For instance, the Department of Defense’s Office of The Chief Financial Officer and the Department of the Interior wanted agencies to have the option to give a disclaimer or not, irregardless of whether or not they made changes to classified information under the new standard (id.). The Department of Energy’s Office of The Chief Financial Officer even felt it would be appropriate to have no disclaimers whatsoever, even if GPFFRs were materially modified (id.).
B. Federal Commentary on Standard 56 Generally
Various government agencies commented on the “meat” of Standard 56, and most were in favor2 of FASAB’s proposals in general. For instance, Housing and Urban Development had fairly positive comments across the board, and deferred greatly to the need to classify information. The organization agreed with all of FASAB’s methodology and conclusions, and stated the new standards would strike a correct balance between protecting classified information and a commitment to open government.
However, oddly enough, the Department of Defense Office of the Inspector General was particularly concerned with the proposed Statement. They wrote “[t]his proposed guidance is a major shift in Federal accounting guidance and, in our view, the potential impact is so expansive that it represents another comprehensive basis of accounting” (FASAB Exposure Draft: Classified Activities, Department of Defense Office of the Inspector General Comment, available at http://files.fasab.gov/pdffiles/CA_8_DoD_OIG.PDF). They suggested already existing methods like redaction are sufficient to protect classified information, and stated the FASAB “should clarify whether this proposed standard, or subsequent Interpretations, could permit entities to record misstated amounts in the financial statements to mislead readers with the stated purpose of protecting classified information. We believe that no accounting guidance should allow this type of accounting entry” (id.).
Additionally, while not quite as critical as the Inspector General, the Treasury expressed concerns about the modification of net results of operations and net position.
C. Concerns From Accounting Firms
The accounting firm Kearney & Company had a more critical take on the proposed standard as well. They worried that “[t]he FASAB’s proposed approach could result in material omissions in GPFFR. . . If GPFFR can be modified so material activity is no longer accurately presented to the reader of financial statements, its usefulness to public users is limited and subject to misinterpretation” (FASAB Exposure Draft: Classified Activities, Kearney & Company Comment, available at: http://files.fasab.gov/pdffiles/CA_14_Kearney_&_CO_.PDF).
The accounting firm KPMG was more concerned with clarity and consistency, stating that because of potential classified interpretations, only some people with clearance will be able to understand the complete set of GAAP. Because of this, “[i]t is not clear how management of each federal entity will be able to assert that their GPFFR have been prepared in accordance with GAAP when management does not have access to all of GAAP” (FASAB Exposure Draft: Classified Activities, KPMG Comment, available at http://files.fasab.gov/pdffiles/CA_2_KPMG.PDF).
V. The Results of Statement 56 for the Public
There is a legitimate existing tension between the need to protect confidential government information and the public’s interest in financial transparency and accountability. Standard 56 isn’t without possible justification. That being said, the concerns of both the accounting world and many within the federal government itself are extremely valid.
Statement 56 undercuts the reliability of government accounting standards and financial statements to such a degree as to render an already questionably valuable reporting tool virtually useless to the public. The possibility of false or omitted information renders the reports largely unreliable as to actual amounts, as does the fact that even an accurate report is rendered questionable by the very existence of modifications that are not necessarily exposed. Classifying portions of the federal GAAP mystifies the process even further, and the fuzzy definitions of reporting entities leaves the potential for this to touch not only direct government entities, but government contractors and other private (but federally entangled) entities. The general disclosure of the government–requiring all reporting entities to report the potential of modifications whether or not they actually exist in their report while simultaneously forbidding the actual disclosure of the actual existence of any modifications–is essentially a worst case in terms of transparency for the public.
VI. About Us
This article was written and edited by Michele Ferri and Jonathan Lurie of The Law Offices of Lurie and Ferri for use by The Solari Report. Michele Ferri and Jonathan Lurie are both practicing attorneys out of California. The Law Offices of Lurie and Ferri focus on working with start-up businesses as well as on intellectual property and business law issues. They can be found at http://www.lflawoffices.com/ or contacted at [email protected].
Sources
FASAB Statement 56: Understanding New Government Financial Accounting Loopholes
January 10, 2019 Solari Staff Articles 13
https://constitution.solari.com/wp-c...-1030x438.jpeg
Table of Contents
I. Introduction
II. History of the Federal Accounting Standards Advisory Board (FASAB)
III. FASAB and Standard 56
A. What Does Standard 56 Do?
B. Reporting Entities Within the Scope of Standard 56
C. Changes to Disclosure Standards Under Standard 56
D. Modifications to Avoid Disclosure of Classified Information
E. Reporting on Consolidation Entities
F. Interpretations Modifying Reporting Standards in the Future
IV. Administrative History of Statement 56
A. Commentary on Required Disclaimers
B. Federal Commentary on Standard 56 Generally
C. Concerns From Accounting Firms
V. The Results of Statement 56 for the Public
VI. About Us
December 29, 2018
I. Introduction
Financial accountability for the government is a cornerstone of a functioning representative democracy. The ability for the people to know where taxpayer money goes to is crucial to having an informed opinion regarding the actions of your representatives and to react accordingly. Unfortunately, as we’ve discussed in previous articles, the current state of government accounting is far from ideal–often bordering on useless to the public. This is largely due to lax enforcement of existing laws such as the Chief Financial Officers (CFO) Act, but also stems from the very real tension between completely transparent government financial disclosure and national security interests (see The U.S. Statutes Creating Modern Constitutional Financial Management and Reporting Requirements and the Government’s Failure to Follow Them, available at https://constitution.solari.com/the-...o-follow-them/). As of the last few months, this tension has taken the future of government financial disclosure to the public to new levels of opacity. The Federal Accounting Standards Advisory Board (FASAB) has released Statement of Federal Financial Accounting Standards 56 (Standard 56), taking government accounting practices from laxly enforced reporting standards to a new benchmark entirely–expressly approved obfuscation of reporting and, in some cases, outright concealing financials.
This sounds fairly alarmist at first blush but, simply put, Standard 56 creates a set of situations where government entities may move numbers around to conceal where money is actually spent or even not report spending outright. Many of the concepts in Standard 56 are not new and have been discussed in FASAB reports for nearly a decade. However, these new changes make a substantial portion of government financial reporting so unreliable as to not be a useful tool to the public (see FASAB Statement of Federal Financial Accounting Standards 56, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
In order to fully understand Standard 56, we will be taking a fairly deep dive on the new accounting standards it creates—from the history leading up to the new rules, to summarizing the exact changes of Standard 56. We’ve said that Standard 56 isn’t new, and this is true; it has hundreds and hundreds of pages of memorandums and the like which came before it, outlining the exact parameters of these new reporting rules. For that reason, a complete summary of what a government entity must report will not be possible–or likely even useful–in an article of this length. That being said, we will explore the role of FASAB itself, the functional changes of Standard 56, and how it will impact the ability of the U.S. taxpayer to see how their money is spent.
II. History of the Federal Accounting Standards Advisory Board (FASAB)
FASAB came about as a response to the requirements of the CFO Act. We previously wrote about the CFO Act in The U.S. Statutes Creating Modern Constitutional Financial Management and Reporting Requirements and the Government’s Failure to Follow Them (available at https://constitution.solari.com/the-...o-follow-them/). Under the Act, the individual CFOs of covered federal agencies are responsible for preparing financial statements for regular audit in order to ensure accuracy in accounting. The CFOs also were tasked by the Act with integrating accounting and budget information into a form consistent with those used to make budgets, put together a uniform financial management system for their agency, and–perhaps most importantly–make sure that the system they put together allowed for actual useful measurement of the financial performance of the CFO’s agency.
However, the CFO Act was light on the details, and after the Act passed in 1990, there was a need to determine the actual details of the accounting standards required. Therefore, the Treasury, OMB, and Comptroller General signed a Memorandum jointly establishing the FASAB to “consider and recommend the appropriate accounting standards for the federal government” (see History of FASAB, available at http://www.fasab.gov/the-history-of-fasab/). Until 1999, FASAB simply gave recommendations to those three sponsoring entities. Then, in 1999, FASAB was approved to set final generally acceptable accounting practices (GAAP) for the federal government, with only a 90 day review period by the sponsoring entities. In 2002, the Treasury was removed as a sponsoring entity, leaving the OMB and GAO as the only entities able to object to FASAB set standards (see id.).
III. FASAB and Standard 56
As mentioned above, since 1999, FASAB sets the final GAAP for the federal government. These practices are then used throughout the federal government to determine the content and structure of the financial reports the CFO Act requires federal government agencies, departments, and the like to prepare. While the GAAP are not themselves literally binding law, they do show what the federal government considers to be compliance with the law. As long as an agency follows GAAP, there will generally be a presumption that it is also complying with the federal financial accounting requirements. Therefore, unless the underlying legislation is amended by Congress, FASAB essentially determines the extent of the federal government’s financial transparency (see id.). With the official adoption of Standard 56 as of October 4, 2018–completely unchanged from the pre-comment period version from July 2018–FASAB has determined that national security concerns essentially trump the need for financial transparency to the public. So how does Standard 56 do this?
A. What Does Standard 56 Do?
In the absolute most simple terms, Standard 56 allows federal entities to shift amounts from line item to line item and sometimes even omit spending altogether when reporting their financials in order to avoid the potential of revealing classified information.1 However, as with all laws, nearly every word in that sentence is a complicated concept to unpack. Who counts as a federal reporting entity? When and how can these entities conceal or remove financial information from their reports? What information can be removed? When does something count as confidential, and who makes that determination? All of these questions have enormous bodies of writing in FASAB memorandums addressing, and sometimes failing to address, their answers.
The simplest place to start with understanding Standard 56 is its scope. It applies to federal entities that issue unclassified general purpose federal financial reports (GPFFR), including where one entity is consolidated with another. This means it only applies to otherwise unclassified financial reports where there is a risk of revealing classified information; classified financial reports are their own can of worms. (See generally, FASAB Statement of Federal Financial Accounting Standards 56, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf). Standard 56 also doesn’t remove the actual requirement to report, it just allows these entities to change their reports in ways that don’t reflect their actual spending (see id.). However, for the purposes of government transparency, determining who is responsible for classifying information, and/or removing that information from unclassified reports, is quite opaque for the average interested citizen.
B. Reporting Entities Within the Scope of Standard 56
The actual reporting entities empowered by the standards of Standard 56 include organizations which are included in the government wide GPFFR (see id.). This includes any entities that are “(1) budgeted for by elected officials of the federal government, (2) owned by the federal government, or (3) controlled by the federal government with risk of loss or expectation of benefits” (FASAB Statement of Federal Financial Accounting Standards 47, p. 1, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf).
However, many different departments, bureaus, and agencies prepare their own GPFFRs as well. The various entities that both prepare their own GPFFR and are within a larger reporting entity are called Component Reporting Entities. This includes executive departments, independent agencies, government corporations, legislative agencies, and federal courts (id. at 7). Their GPFFRs are then consolidated into the government wide GPFFR.
Under the Component Reporting Entities and included in their GPFFRs are various other organizations, from smaller departments to government contractors, which are split into two categories: disclosure entities and consolidation entities (see id.).
Consolidation entities are entities like agencies and departments. A consolidation entity generally (1) is financed through taxes and other non-exchange revenues, (2) is governed by the Congress and/or the President, (3) imposes or may impose risks and rewards to the federal government, and (4) provides goods and services on a non-market basis (see id. at 16). For instance, a department or corporation established by Congress to perform a government function is a classic example of a consolidation entity. Consolidated entities are reported by a larger entity as part and parcel of their financial reporting–as if they were one economic entity. We will discuss this type of entity later in great depth, as it constitutes one of the largest potential loopholes of Standard 56 (see id.).
Disclosure entities are financially independent organizations. These organizations still need to be included in the government wide GPFFR, but do not fully meet the four characteristics of consolidated entities above. They include quasi-governmental entities, organizations in receiverships and conservatorships, and organizations owned or controlled through federal government intervention actions (see id. at 16). A good example would be government-established non-profits that have a significant portion of their board appointed by the President but are entirely funded by their own activities.
Additionally, there are “related parties,” which are organizations where at least one of the parties involved has the ability to exercise significant influence over the policy decisions of the other party. This significant influence does not need to amount to control, but can include things such as representation on a board of directors, participation in policy making procedures, shared managerial personnel, and things along those lines. The existence of significant influence is generally determined through a full analysis of the particulars of each situation. This classification is usually applied to organizations that do not even rise to the level of a disclosure entity, but nonetheless would be misleading to exclude. Some common examples of related parties are some government-sponsored enterprises and organizations governed by representatives from each of the governments that created the organization, including the United States, wherein the federal government has agreed to ongoing or contingent financial support to accomplish shared objectives. Related entities generally do not include government contractors, government vendors, some non-profits, organizations created by treaty, or special interest groups–although they can in the right circumstances (see id. at 7 and 31-33).
However, there are also certain entities that would probably be consolidation or disclosure entities, but are expressly excluded from the government wide GPFFR: the Federal Reserve System and bailout entities (see Financial Report of the United States Government 2016, p. 227, available at https://fiscal.treasury.gov/files/re...FR-(Final).pdf). In particular, this includes entities like Freddie Mac and Fannie Mae (see id.). If the government obtains rights in another entity which would give them the sort of control that normally makes a disclosure entity, but gains those rights when it “guarantee[s] or pay[s] debt for a privately owned entity whose failure could have an adverse impact on the nation’s economy, commerce, national security, etc. . .” those rights don’t count for determining a reporting entity (id).
This means that in addition to consolidation and disclosure entities, the scope of Standard 56 stretches to any organization which it would be misleading to exclude but isn’t otherwise incorporated into their list of covered entities. Because of this, although there is not a exhaustive list of whose financial reporting is impacted by Standard 56, if you can think of an entity related to the government, it is a safe bet they count as a covered reporting entity. This can include publicly traded corporations with significant funding and/or control from the federal government.
C. Changes to Disclosure Standards Under Standard 56
For these covered entities, Standard 56 offers financial reporting exceptions in a few situations for national security purposes. These reporting exceptions are the meat of Standard 56, three rules substantially modifying the reporting requirements of the above discussed entities to varying degrees (see FASAB Statement of Federal Financial Accounting Standards 56, p. 6, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
In general, disclosure entities are required to provide their financial reporting in a manner which is clear, concise, meaningful, and transparent (see FASAB Statement of Federal Financial Accounting Standards 47, para 71-73, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf). This is done through a single, integrated report of finances disclosing the relationship of the organization to the government and related entities, the nature and magnitude of their activity and their financial balances, and a description of financial and non-financial risks, potential benefits, and, if possible, the amount of the federal government’s exposure to gains and losses from the past or future operations of the disclosure entity or entities (see id. at para 74). This generally includes how much control or influence over the entity is exercised, key terms in their contractual agreements, percentage ownership and voting rights, a summary of assets, liabilities, revenues, expenses, gains and losses, key financial indicators, information on how their reports are stored and can be obtained, and quite a bit more (see id.). Essentially what is required is a transparent summary of how money is spent to provide accountability to the public. Standard 56 creates three loopholes to this disclosure standard.
D. Modifications to Avoid Disclosure of Classified Information
The first new loophole allows disclosure entities to modify their financial reports to “prevent the disclosure of classified information in an unclassified GPFFR” so long as these modifications do not change the net results of operations and net position. (See FASAB Statement of Federal Financial Accounting Standards 56, p. 6, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
This ultimately means that, when done to conceal confidential information, entities can–and are essentially required to under the terms of Standard 56–shift money from one line item to another so long as the totals stay consistent. The rule also allows entities to omit the line item entirely while retaining the amounts so as to maintain the same net results. This means that readers of these reports will never know if the amounts reported spent on specific projects or things are an accurate representation (see id.). As you might expect given the rationale of this being a national security precaution, there will not be any narrative in these reports explaining or revealing where a modification has taken place (see id.). If they can maintain net position in their reports, an entity can even omit a project entirely by folding it into another department or project within the same entity.
While it could obviously be worse for transparency purposes, the alternative would be that the amounts would just be omitted entirely. That brings us to the next two changes to accounting standards created by Standard 56.
E. Reporting on Consolidation Entities
We briefly discussed consolidation entities above as one of the larger loopholes to reporting within Standard 56. This is because the second change to reporting requirements of Standard 56 allows the reporting entity which the consolidation entity is consolidated with to modify reports to avoid disclosure of confidential information even if that modification changes net results of operations or net position. The reporting entity can move the financials of the consolidation entity or even choose not to include it in its report; full stop. (See FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7, available at http://files.fasab.gov/pdffiles/handbook_sffas_56.pdf).
The concept of consolidation entities being incorporated into the reports of a larger reporting entity is far from new. FASAB has memorandums detailing the rules regarding consolidation from as far back as 2012 (see FASAB Federal Reporting Entity Memorandum, November 29, 2012, available at http://files.fasab.gov/pdffiles/tab_...al_2012dec.pdf). By itself, it is not a particularly problematic issue. Under FASAB rules, consolidation in financial reporting is appropriate for those organizations financed by the taxpayer, governed by elected or appointed officials, imposing risks and rewards on the taxpayer, and providing goods and services on a non-market basis. However, consolidation is not appropriate for organizations operating with a high degree of autonomy (see id. at 7).
In general, where an organization is controlled by the federal government and stands to make or lose money, but doesn’t have enough independence for a disclosure entity, it is included somewhere as a consolidation entity (see FASAB Statement of Federal Financial Accounting Standards 47, pp. 14-15, available at http://files.fasab.gov/pdffiles/handbook_sffas_47.pdf). As you’ve seen, the determination of what sort of entity something is hinges a great deal on the level of autonomy of the entity–the greater the control the government has, the more likely something will be classified as a consolidation entity. This control doesn’t mean the government has to actively manage on the day-to-day, but does require an examination of–among other things–whether the government can do things like appoint a majority of board members, dissolve the organization, authorize or deny action within the organization on some or all issues, or direct the policies or use of assets within the organization, and/or direct investment decisions. Consolidation entities are only assigned to one component entity and, in general, where that sort of control exists for a consolidated entity, the public would rely on the larger reporting entity for information on the consolidation entity’s financials (see id.). Under the second accounting standard change within Standard 56, the public can’t even count on these financials being reported in the first place (see FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7).
F. Interpretations Modifying Reporting Standards in the Future
The final change to accounting standards within Standard 56 doesn’t do much at the moment, but has the greatest potential to undermine financial transparency in the future. It allows FASAB to issue Interpretations of Standard 56 in the future which would allow other modifications to financial reports for the purpose of avoiding disclosure of classified information. FASAB can, and likely will, release these Interpretations over time. These Interpretations can allow modifications to reporting without regard for maintaining an entity’s net results or net position in their reporting. Those interpretations may even be classified themselves (Appendix A, A16), resulting in a portion of the federal government’s accountability standards being concealed from the public (see FASAB Statement of Federal Financial Accounting Standards 56, pp. 6-7).
Looked at in the most optimistic light, this will allow FASAB to ensure that Standard 56 isn’t abused and issue rulings of when disclosure is necessary in situations not yet considered. Looked at in a less optimistic light, this means that the ability of the government to obfuscate financial records will continue to grow in the coming months and years, without public oversight, as Interpretations add to or clarify these existing loopholes.
IV. Administrative History of Statement 56
Statement 56, and its reporting exceptions, have been in the works within FASAB for months. When an issue is identified, FASAB performs preliminary deliberations, prepares the initial documents, and then releases a review version to the public for comment and public hearings. After the comment period, FASAB enters further deliberations to consider the comments and make revisions. Then, the Board approves the proposed statement by a two-thirds majority vote, and submits it to the principals (the OMB and the GAO) for review. If neither principal objects to the proposal after 90 days, it is published by FASAB and is added to the GAAP for federal entities (Definition: FASAB (Federal Accounting Standards Advisory Board), available at https://searchcompliance.techtarget....Advisory-Board).
For Standard 56, the exposure draft was published on July 12, 2018, with comments due by August 13, 2018. Seventeen comments were submitted by various departments, agencies, and accounting firms (see FASAB Classified Activities, available at http://fasab.gov/ca/). The final Statement 56 was published on October 4, 2018, with little if any change from the exposure draft. However, the comments on Statement 56 are themselves interesting and somewhat enlightening.
A. Commentary on Required Disclaimers
FASAB proposed two possible alternatives for disclosure/disclaimer requirements under Standard 56. Either reporting entities could be given a choice in whether or not to consistently disclose that certain presentations may have been modified, or all reporting entities must disclose the possibility that certain presentations may have been modified, regardless of actual modification (see FASAB Exposure Draft Interpretation of Federal Financial Accounting Standards 56: Classified Activities, available at https://fas.org/sgp/news/2018/07/fasab-review.pdf).
The SEC gave a fairly entertaining comment on Standard 56. After answering “No Comment” to literally every preceding question, the SEC gave its thoughts on FASAB’s proposal for how component entities should disclose that they have modified their reports. The SEC, the nation’s foremost agency in the fight against financial fraud, doesn’t think that every component entity should have to disclose that modifications may have occurred, and especially the SEC shouldn’t have to. The reasoning the SEC gave for this position was that they “believe that this would be misleading and likely to cause confusion for financial statement readers, by implying that SEC is involved in classified activities. It’s likely that SEC, as well as other agencies, would receive numerous inquiries from the public and from the media by including such an unexpected disclaimer in its financial statements.” In other words, they’re worried it would look strange to the public if they disclosed that they had modified their financial reporting, despite no such modification. The public may think it odd that component entities such as the SEC would make such a, in their own words, “unexpected disclaimer” (FASAB Exposure Draft: Classified Activities, SEC Comment, available at http://files.fasab.gov/pdffiles/CA_13_SEC.PDF).
Veterans Affairs and the Association of Government Accountants had a similar stance, and while they commented on other aspects of Standard 56 as well, they joined the SEC in criticizing a mandatory disclaimer, and suggested disclaimers would only be appropriate when GPFFRs were actually modified (see FASAB Classified Activities, available at http://fasab.gov/ca/).
Several other commenting parties had a different take on the required disclaimers. For instance, the Department of Defense’s Office of The Chief Financial Officer and the Department of the Interior wanted agencies to have the option to give a disclaimer or not, irregardless of whether or not they made changes to classified information under the new standard (id.). The Department of Energy’s Office of The Chief Financial Officer even felt it would be appropriate to have no disclaimers whatsoever, even if GPFFRs were materially modified (id.).
B. Federal Commentary on Standard 56 Generally
Various government agencies commented on the “meat” of Standard 56, and most were in favor2 of FASAB’s proposals in general. For instance, Housing and Urban Development had fairly positive comments across the board, and deferred greatly to the need to classify information. The organization agreed with all of FASAB’s methodology and conclusions, and stated the new standards would strike a correct balance between protecting classified information and a commitment to open government.
However, oddly enough, the Department of Defense Office of the Inspector General was particularly concerned with the proposed Statement. They wrote “[t]his proposed guidance is a major shift in Federal accounting guidance and, in our view, the potential impact is so expansive that it represents another comprehensive basis of accounting” (FASAB Exposure Draft: Classified Activities, Department of Defense Office of the Inspector General Comment, available at http://files.fasab.gov/pdffiles/CA_8_DoD_OIG.PDF). They suggested already existing methods like redaction are sufficient to protect classified information, and stated the FASAB “should clarify whether this proposed standard, or subsequent Interpretations, could permit entities to record misstated amounts in the financial statements to mislead readers with the stated purpose of protecting classified information. We believe that no accounting guidance should allow this type of accounting entry” (id.).
Additionally, while not quite as critical as the Inspector General, the Treasury expressed concerns about the modification of net results of operations and net position.
C. Concerns From Accounting Firms
The accounting firm Kearney & Company had a more critical take on the proposed standard as well. They worried that “[t]he FASAB’s proposed approach could result in material omissions in GPFFR. . . If GPFFR can be modified so material activity is no longer accurately presented to the reader of financial statements, its usefulness to public users is limited and subject to misinterpretation” (FASAB Exposure Draft: Classified Activities, Kearney & Company Comment, available at: http://files.fasab.gov/pdffiles/CA_14_Kearney_&_CO_.PDF).
The accounting firm KPMG was more concerned with clarity and consistency, stating that because of potential classified interpretations, only some people with clearance will be able to understand the complete set of GAAP. Because of this, “[i]t is not clear how management of each federal entity will be able to assert that their GPFFR have been prepared in accordance with GAAP when management does not have access to all of GAAP” (FASAB Exposure Draft: Classified Activities, KPMG Comment, available at http://files.fasab.gov/pdffiles/CA_2_KPMG.PDF).
V. The Results of Statement 56 for the Public
There is a legitimate existing tension between the need to protect confidential government information and the public’s interest in financial transparency and accountability. Standard 56 isn’t without possible justification. That being said, the concerns of both the accounting world and many within the federal government itself are extremely valid.
Statement 56 undercuts the reliability of government accounting standards and financial statements to such a degree as to render an already questionably valuable reporting tool virtually useless to the public. The possibility of false or omitted information renders the reports largely unreliable as to actual amounts, as does the fact that even an accurate report is rendered questionable by the very existence of modifications that are not necessarily exposed. Classifying portions of the federal GAAP mystifies the process even further, and the fuzzy definitions of reporting entities leaves the potential for this to touch not only direct government entities, but government contractors and other private (but federally entangled) entities. The general disclosure of the government–requiring all reporting entities to report the potential of modifications whether or not they actually exist in their report while simultaneously forbidding the actual disclosure of the actual existence of any modifications–is essentially a worst case in terms of transparency for the public.
VI. About Us
This article was written and edited by Michele Ferri and Jonathan Lurie of The Law Offices of Lurie and Ferri for use by The Solari Report. Michele Ferri and Jonathan Lurie are both practicing attorneys out of California. The Law Offices of Lurie and Ferri focus on working with start-up businesses as well as on intellectual property and business law issues. They can be found at http://www.lflawoffices.com/ or contacted at [email protected].
Sources
- FASAB
________________
1 The extent of what qualifies as classified or confidential information is determined by Executive Order 13526 (the most recent standard set back in 2009), changes over time, and could fill a book by itself. (https://www.archives.gov/isoo/policy...s/cnsi-eo.html).
2 The Departments of Veterans Affairs, Housing and Urban Development, Energy, and The Interior, all had agreement with the proposed standard more or less across the board, with a few exceptions for disagreements about the disclaimers.
6 COMMENTS
- https://secure.gravatar.com/avatar/3...?s=50&d=mm&r=gKevine Riner says:
JANUARY 15, 2019 AT 3:55 AM
Can I share this article? I put the title and source on FB and my friends reacted to the story.
REPLY - https://secure.gravatar.com/avatar/3...?s=50&d=mm&r=gKevine Riner says:
JANUARY 15, 2019 AT 4:05 AM
I wish it was possible to share this excellent article with my friends online so they can better understand what a can of worms our government is today. Especially at this time in history when anything embarrassing to or corruptions within agencies is deemed classified.
REPLY- https://secure.gravatar.com/avatar/4...?s=50&d=mm&r=gCatherine Fitts says:
JANUARY 28, 2019 AT 5:19 AM
This article is public. Please feel free to share with anyone you like. We try to make pieces that we write or commission that impact our most important policy issues open to the public.
- https://secure.gravatar.com/avatar/4...?s=50&d=mm&r=gCatherine Fitts says:
- #6,658
- Jun 3, 2019 5:41am Jun 3, 2019 5:41am
- | Commercial User | Joined Dec 2014 | 14,164 Posts
Inserted Video
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- Jun 3, 2019 5:42am Jun 3, 2019 5:42am
- | Commercial User | Joined Dec 2014 | 14,164 Posts
Inserted Video
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- Edited 6:05am Jun 4, 2019 4:45am | Edited 6:05am
- | Commercial User | Joined Dec 2014 | 14,164 Posts
https://www.zerohedge.com/news/2019-...ops+to+zero%29
Somewhere, Albert Edwards is doing a victory lap. Little by little, the SocGen strategist's "IceAge" thesis, which sees US 10Y Treasury rates eventually catching down to Bunds and JGBs by hitting 0% and going negative thereafter as a deflationary singularity grips the entire world, is materializing.
https://zh-prod-1cc738ca-7d3b-4a72-b...s%20iceage.jpg
On Monday, the market found a newfound appreciation for Edwards' gloomy perspective, as September eurodollars soared 14.5 ticks following Bullard comments greenlighting a Fed rate cut. The EDM9-EDZ9 has plunged, more than doubling in just a few days as low as -0.485 bps today, in a move that shocked rates traders and left them speechless as the market is now pricing in a 60% chance of two cuts or more by September.
https://zh-prod-1cc738ca-7d3b-4a72-b...ges/EDM9Z9.jpg
But it's no longer just Albert who sees a deflationary tsunami flooding over the US. The grouchy permabear was joined by billionaire Stan Druckenmiller, who said he could see the Fed funds rate going to zero in the next 18 months if the economy softens, and that he recently piled into Treasuries as the U.S. trade war with China escalated.
"When the Trump tweet went out, I went from 93% invested to net flat, and bought a bunch of Treasuries," Druckenmiller said Monday evening quoted by Bloomberg, referring to the May 5 tweet from Trump which threatened an increase in tariffs on China and which sparked the most vicious bout of trade-war related selling yet. Explaining his decision, Druck said that it's “not because I’m trying to make money, I just don’t want to play in this environment."
Incidentally, for those confused what going from 93% invested to flat means, the answer is he liquidated his entire equity book.
In an interview by Key Square Capital Management founder Scott Bessent at The Economic Club of New York, Druckenmiller went against conventional, and Beijing, wisdom which believes that Trump will capitulate ahead of the 2020 elections, and said that at the moment he doesn’t see Trump giving China room for negotiation because the president sees tariffs as a winning strategy for the 2020 election. That, of course, could change if the economy and markets get weaker, he said.
"If you can analyze Donald Trump more power to you. I've been more wrong footed by this guy, and shame on me", Druckenmiller summarized his feelings toward Trump.
At the same time, as we noted earlier when we pointed out that several of Druckernmiller's key warning indicators are flashing an "amber alert", while the former chief strategist for George Soros wouldn’t say whether the U.S. is headed for a recession, he said he sees "many warning signs" adding that he was concerned that Trump may have broken a fragile economy going into the next election and assumes he won’t be re-elected in 2020.
Looking at other asset classes, Druckenmiller said that while Treasuries have become less interesting amid the furious rally in recent days, they remain "the best game in town" if the economy deteriorates, and certainly if rates tumble another 2% to zero or below. “Gold’s not bad either,” he added.
As we reminded readers earlier today, last December Druckenmiller warned that trading conditions could worsen, and that while the indicators he historically used were not red yet...
https://zh-prod-1cc738ca-7d3b-4a72-b...indicators.jpg
... they were deep inside amber territory. Alongside former Fed governor Kevin Warsh, Druck also urged the Federal Reserve not to raise rates in December, and while central bank did not follow his advice that time, it has since kept interest rates steady and may cut rates as soon as the June meeting which is suddenly seen as "live."
Below, courtesy of Bloomberg, are some other highlights from the interview of the hedge fund legend whose average returns of 30% over three decades, speaks for itself:
Somewhere, Albert Edwards is doing a victory lap. Little by little, the SocGen strategist's "IceAge" thesis, which sees US 10Y Treasury rates eventually catching down to Bunds and JGBs by hitting 0% and going negative thereafter as a deflationary singularity grips the entire world, is materializing.
https://zh-prod-1cc738ca-7d3b-4a72-b...s%20iceage.jpg
On Monday, the market found a newfound appreciation for Edwards' gloomy perspective, as September eurodollars soared 14.5 ticks following Bullard comments greenlighting a Fed rate cut. The EDM9-EDZ9 has plunged, more than doubling in just a few days as low as -0.485 bps today, in a move that shocked rates traders and left them speechless as the market is now pricing in a 60% chance of two cuts or more by September.
https://zh-prod-1cc738ca-7d3b-4a72-b...ges/EDM9Z9.jpg
But it's no longer just Albert who sees a deflationary tsunami flooding over the US. The grouchy permabear was joined by billionaire Stan Druckenmiller, who said he could see the Fed funds rate going to zero in the next 18 months if the economy softens, and that he recently piled into Treasuries as the U.S. trade war with China escalated.
"When the Trump tweet went out, I went from 93% invested to net flat, and bought a bunch of Treasuries," Druckenmiller said Monday evening quoted by Bloomberg, referring to the May 5 tweet from Trump which threatened an increase in tariffs on China and which sparked the most vicious bout of trade-war related selling yet. Explaining his decision, Druck said that it's “not because I’m trying to make money, I just don’t want to play in this environment."
Incidentally, for those confused what going from 93% invested to flat means, the answer is he liquidated his entire equity book.
In an interview by Key Square Capital Management founder Scott Bessent at The Economic Club of New York, Druckenmiller went against conventional, and Beijing, wisdom which believes that Trump will capitulate ahead of the 2020 elections, and said that at the moment he doesn’t see Trump giving China room for negotiation because the president sees tariffs as a winning strategy for the 2020 election. That, of course, could change if the economy and markets get weaker, he said.
"If you can analyze Donald Trump more power to you. I've been more wrong footed by this guy, and shame on me", Druckenmiller summarized his feelings toward Trump.
At the same time, as we noted earlier when we pointed out that several of Druckernmiller's key warning indicators are flashing an "amber alert", while the former chief strategist for George Soros wouldn’t say whether the U.S. is headed for a recession, he said he sees "many warning signs" adding that he was concerned that Trump may have broken a fragile economy going into the next election and assumes he won’t be re-elected in 2020.
Looking at other asset classes, Druckenmiller said that while Treasuries have become less interesting amid the furious rally in recent days, they remain "the best game in town" if the economy deteriorates, and certainly if rates tumble another 2% to zero or below. “Gold’s not bad either,” he added.
As we reminded readers earlier today, last December Druckenmiller warned that trading conditions could worsen, and that while the indicators he historically used were not red yet...
https://zh-prod-1cc738ca-7d3b-4a72-b...indicators.jpg
... they were deep inside amber territory. Alongside former Fed governor Kevin Warsh, Druck also urged the Federal Reserve not to raise rates in December, and while central bank did not follow his advice that time, it has since kept interest rates steady and may cut rates as soon as the June meeting which is suddenly seen as "live."
Below, courtesy of Bloomberg, are some other highlights from the interview of the hedge fund legend whose average returns of 30% over three decades, speaks for itself:
- No impeachment: It would “be crazy” at this point to try to remove Trump through impeachment or the 25th amendment, because it would take too long and “the country would go through hell. It doesn't make sense"
- Major shake-out in the hedge fund industry is coming: “There’s probably five to 10 people, women and men, who are worth more than their fees now,” he said. “There are still going to be superstars, but we need to get back to maybe 200 or 300 from 4,000” funds.
- Staying away from bitcoin: He wouldn’t be short or long Bitcoin, as he doesn’t understand why it’s a store of value. “I don’t think I’m a neanderthal, which is what I’ve been called when I’ve said I didn’t want to own Bitcoin.”
Druckenmiller's parting words were the most memorable. Responding to a question from the audience if the Fed is going to use negative rates, here's what Druckenmiller said:
"They're going to do the works. Stuff that I thought was brilliant in 2009 and should be used once every 50 years is now being discussed as part of the toolkit even for like a recession.
I can easily see 2 Years easily going to zero, and I would say the odds are very high they would cut 50 to a 100 bps in the next year. Everything I see out of central banks globally is radical policies ahead."
His full interview is below.
PLEASE LISTEN:
https://www.zerohedge.com/news/2019-...JFT3K1PaPi_4XI