Hidden risks of hedge accounting in financial institutions: A study of Franklin Savings Association

Abstract

The hedge accounting standards for financial institutions stipulated in SFAS No. 80 impose ambiguous guidelines whose enforcement can produce detrimental effects on the financial condition of institutions. Combining these standards with the interpretive authority of regulatory agencies can subject institutions to regulatory risk-the risk of an adverse regulatory ruling resulting from disparate interpretations of the accounting standards. The accounting regulations specified in SFAS No. 80 permit financial institutions to defer derivative-contract losses over the life of the underlying asset or liability. If the hedge designation is misused, however, the capital position of the institution may potentially be misstated prior to maturity of the derivative contracts. Further, when a hedging program goes awry, the current hedge accounting standards may actually encourage the shift to what is actually a speculation program by permitting a larger asset base on which to “earn back” a portion of the hedging losses. Thus, institutional programs initially designed to mitigate interest-rate risk can instead become risk-increasing, separate profit centers. Events leading to the RTC conservatorship of Franklin Savings Association are used to illustrate the opportunities and regulatory threats inherent in hedge accounting. Subsequent analysis indicates that similar ordeals could be avoided by a clarification of hedge accounting standards, the consistent application of standards by regulators, or by increasing capital requirements for those institutions that use derivatives as separate profit centers as opposed to hedging risk exposures.