From Gatekeepers to Gateway Constructors – the social role of credit rating agencies

Editorial Note: We are delighted to “go global” and welcome the following contribution by Dr Stewart Smyth of the University of Sheffield, UK. 

We welcome contributions by all members of the academic and business communities who maintain an interest in Accounting and the Public Interest. Please direct your queries to Michael Kraten at mkraten@hbu.edu.

As always, when you read the comments of our columnists, please keep in mind that they only speak for themselves. They are not expressing the positions of the AAA or of any other party.

Over the summer Critical Perspectives on Accounting published a paper I co-authored on the role of credit rating agencies in the process of financialising social housing providers in London. In the style of the TV show, Jeopardy!, the paper is the answer to the question – What is the research outcome when a geography, a housing studies and an accounting academic collaborate?

During our initial discussions credit rating agencies (CRAs) barely warranted a mention, we were more focused on the impact that large amounts of debt finance was having on the provision of below market-rents accommodation in a city that has become a location to store excess capital for the global billionaire class. However, two UK-based colleagues – Thomas Wainwright and Graham Manville – beat us to the punch, publishing an excellent article on innovation in the social housing bond market.

Rating agencies hone into view

The innovation Wainwright and Manville explore is the manner in which not-for-profit organisations, often with a charitable heritage, are increasingly turning to the capital debt markets for finance and issuing their own corporate bonds. In England, up to the turn of the century a social housing provider issuing a corporate bond was almost unheard of – by 2017 there was a cumulative total of 84 bond issues by 58 housing providers, worth £17.1 billion.

The increased activity in this form of finance comes from a combination of severe cuts in government grants during the austerity years and a reluctance by the traditional financers of this sector, banks, to fund over the long term (i.e. a 30-year business plan) after the financial crash of 2008.

Of course, every bond issued by a social housing provider requires at least one credit rating and an ongoing relationship with a rating agency afterwards. However, my co-authors and I were aware that credit rating agencies had been implicated in the 2007/08 credit crunch and following financial crash, and we wondered what impact their rating methodologies have had on the operation of social housing providers.

Rating agencies – a history

For much of their history CRAs have been considered peripheral to the operation of business, often having a quasi-academic image. With roots in the commercialisation of emergent business financial information during the nineteenth century, CRAs started to become key actors in capital and financial markets from the 1970s, in the main due to changes in regulation by the SEC and subsequently under the Basel capital adequacy rules for banks.

In that decade CRAs also changed their business model by securing fees from those issuing financial instruments, (rather than those buying them). This change created similar relations to those in the auditing industry with related conflicts, such as being paid by those you are forming an opinion on and the opportunity to sell ancillary services.

However, it is in recent decades, with the increasing financialisation of the world economy, that CRAs’ revenue and power has grown substantially. For example, in the fifteen years to 2015 Moody’s global revenue grew by US$ 602 million to total US$ 3.5 billion. Further, Moody’s describes themselves as “… an essential component of the global capital markets” which contributes to transparent and integrated financial markets.

Yet, CRAs have been criticised not just in relation to the 2008 global financial crisis but also for not being able to predict the 1997 Asian currency crisis or the collapse of Enron. For example, in the wake of the Enron bankruptcy, Senator Joe Liberman said,

The credit-rating agencies were dismally lax in their coverage of Enron. They didn’t ask probing questions and generally accepted at face value whatever Enron’s officials chose to tell them. And while they claim to rely primarily on public filings with the SEC, analysts from Standard and Poor’s not only did not read Enron’s proxy statement, they didn’t even know what information it might contain.

Not only gatekeepers …

Despite this history and the central role now afforded to CRAs in the operation of the capital markets we know very little about their operation in general and specifically with regards to the impact their work has on the operation of those they rate. Much of the research completed to date places CRAs in a principle-agent relationship, where they act as a reputational intermediary to reassure financial investors.

In this way CRAs are seen as gatekeepers for those entering the capital markets to secure bond (or other) finance.

In our paper we seek to understand the role of CRAs by drawing on the smaller stream of work that utilises a political economy understanding. In this understanding credit ratings are, as Timothy Sinclair has argued, a surveillance system for secure capital mobility across geographical and cultural space.

This idea of capital’s mobility across cultural space is particularly relevant in our case study with ratings being provided for not-for-profit organisations delivering a public service. The idea of movement also allowed us to flip the gatekeeper metaphor round and look at the rating activity from the perspective of the finance providers.

but gateway constructors

Hence, we were able to theorise, and show empirically in the paper, that credit rating agencies also construct gateways that enable private capital’s movement into a new space, i.e. social housing.

The gateway construction occurs through a number of activities but a central one is that through the process of securing a rating the debt issuer learns to speak the same language as the finance provider. As one of our interviewees stated,

I mean it does educate us when we go out to investors … [to] do a road show. So, we would have had the experience of a credit rating before one of them and when you go into the investors you’re talking the same language.

Alongside, the new language we show how the social housing providers internalise the priorities of finance capital, through the rating process by changing their internal reporting and decision-making activities. For example, taking key accounting ratios that are preferred by the CRAs into their new build and development decisions.

The financialisation of everything

Since the turn of the century, research on financialisation has tended towards either macro studies of changes in the global processes of capital accumulation or a micro-level focus on individual companies where the short-termism of the shareholder value revolution pre-dominates. Our study focuses on a fine-grained analysis of financialisation processes at a meso-level (i.e. the social housing sector), where credit rating agencies play a crucial, even decisive role.

The members of this sector have been described as hybrid organisations – as the 2014 front cover of one social housing provider’s annual report proclaimed “Socially hearted, commercially minded”. The policy and funding environment over the past ten-years has increased the commercially-minded activities of the social housing providers by securing finance from the capital markets and is enabled by credit rating agencies.

Ultimately this leads us to conclude that credit rating agencies do not play a neutral or independent role in verifying accounting and commercial information but are active participants in the extension of financial logics and practices to ever more areas of human activity; in other words, CRAs facilitate the financialisation of everything.

STEWART SMYTH

Dr Stewart Smyth works at the University of Sheffield, UK where he is director of the Centre for Research into Accounting and Finance in Context (CRAFiC). Stewart is also the chairperson of the Interdisciplinary Perspectives Special Interest Group, of the British Accounting and Finance Association (BAFA).

The paper this blog is based on is freely available under open access rules at the following link:

Smyth, S.; Cole, I. and Fields, D. (2019/forthcoming), “From gatekeepers to gateway constructors: Credit rating agencies and the financialisation of housing associations”, Critical Perspectives on Accounting

A Public Interest Debate!

On March 14, 2019, our Contributing Columnist Rick Kravitz, the Editor In Chief of the CPA Journal, authored a blog post entitled “Reimagining a More Ethical and Sustainable Management Accounting Curriculum.” In that post, he asserted that:

The accounting curriculum, while relevant 40 years ago, has lost much of its relevance today in our post-modern global economy. Accounting education fails to account for the real drivers of enterprise growth in the digital economy.

That drew a rebuttal from Dr. Lawrence Murphy Smith, CPA, a Professor of Accounting at Texas A&M University-Corpus Christi. According to Murphy:

Since I was an accounting student more than 40 years ago, people within and outside the profession have lamented that accounting and financial reporting isn’t doing a good job of providing useful information.

In the editorial column, “Reimagining a More Ethical and Sustainable Management Accounting Curriculum” by Richard Kravitz, this complaint appears once again. On the upside, accountants should be constantly working to ensure the usefulness of accounting and financial reporting. On the downside, this article way overstates the lack of value of accounting information.

The most important piece of accounting information, I would argue, is net income/profit. That number is still calculated, just as it has been through the centuries. To a very large extent the current value and future projected value of net income/profit drives the market value of virtually every modern-day company, whether that market value is 100 times the book value or one times the book value. So, accounting/financial reporting is still relevant; it always has been.

Of course, there will always be exceptions to the predictive power of financial reports. Exceptions result from new technologies, innovative new products, economic cycles, fraudulent financial reporting, brilliant and dismal company leadership, politics, and unexpected events. For example, before the Internet, few people could predict its massive impact on business, which enabled Amazon to become the second largest retail store in the U.S., second only to Walmart. After reading about a very profitable airline company in the summer of 2001, I invested. There was no public awareness that Islamic terrorists were plotting the attack on the World Trade Center. Not long after September 11, 2001, my airline stock was worthless.

The past cannot always predict the future, and by their nature, financial reports are about the past. So, while financial reports are extremely helpful, they cannot guarantee future outcomes. I would argue that financial reports provide a critical part, if not the majority, of information supporting investment decisions. When people are willing to buy stock in a company with giant losses, those people are taking the risk that the company will turn around and make profits in the future. In effect, the future projected value of net income is driving the company’s market value. Sometimes a company turns things around and sometimes it doesn’t. While financial reports are still very relevant in predicting future prospects of most companies, in the final analysis, only God knows the future with absolute certainty.

In conclusion, I have the highest regard for Rick Kravitz and Baruch Lev but I respectfully disagree with their negative assessment of the value of financial statements.

That, in turn, drew a rebuttal to the rebuttal from Rick! He noted:

I would ask the good professor how he can conclude this when Uber, Tesla, Lyft, and dozens of other cash burning companies now have losses in the trillions of dollars and yet possess positive share value. Bad reporting by accountants caused 55 billion dollars of shareholder losses last year, the highest since the Great Recession. And according to Baruch Lev, the information content of the financial statements only constitutes 3% to 4% of information that supports investment decision. What a lack of relevance!

The debate clearly rages on. It clearly will not be resolved in the near future. Nevertheless, our Public Interest Section is delighted to host a professional forum for this lively conversation.

Using the PLUS Ethical Decision Making Model to Teach Ethics to Accounting Students

Editorial Note: It’s time to go “back to school” as we begin the traditional academic year! In the spirit of the season, we’re pleased to feature the following piece by Contributing Columnist Steve Mintz on accounting education.

Steve is one of three regular columnists who have agreed to author a blog post every quarter. All posts are distributed via email, and are published online at AAAPublicInterest.org.

We welcome contributions by all members of the academic and business communities who maintain an interest in Accounting and the Public Interest. Please direct your queries to Michael Kraten at mkraten@hbu.edu.

As always, when you read the comments of our columnists, please keep in mind that they only speak for themselves. They are not expressing the positions of the AAA or of any other party.

It’s time now for accounting educators to rethink the scope of decision-making models used to teach accounting ethics. If ethical issues that arise in the context of organizational culture are not dealt with properly then it is less likely ethical conflicts can be resolved. Consideration of the internal systems within organizations is what’s missing from traditional decision-making models and should be given a more prominent role.

Ethical Decision Making

Accounting educators typically use an ethical decision-making model to teach ethics to accounting students. Ethical decision models provide a systematic way to think through ethical issues, identify alternative courses of action, evaluate the ethics of each alternative and decide what to do.

Traditionally, the decision-making models used to teach ethics to accounting students have focused on applying philosophical reasoning methods to the analysis of what should be done. These models tend to downplay or ignore the importance of organizational culture in the decision-making process including internal policies and practices, the code of ethics and individuals in the organization who might serve as supporters to help resolve conflicts.

Given the added focus on organizational ethics since passage of the Sarbanes-Oxley Act and the profession’s recognition of the importance of the control environment, accounting educators should look for new ways to incorporate organizational factors to make the ethics curriculum more relevant. Moreover, the AICPA Code of Professional Conduct now addresses ethical conflicts and describes the process to resolve them including internal steps.

The PLUS Ethical Decision Making Model

The PLUS Ethical Decision Making Model was developed through The Ethics Resource Center, the research arm of the Ethics & Compliance Initiative (ECI). The ECI is a community of organizations that are committed to creating and sustaining high quality ethics and compliance programs to assist organizations in building strong cultures. The mission of ECI is to assist its members across the globe to operate their businesses at the highest levels of integrity.

The PLUS Model is based on a seven-step process described below. The word PLUS refers to ethics filters that facilitate the analysis of ethics considerations and implications of the decision at hand. The filters ensure that ethical issues rise to the forefront in ethical decision making. The mnemonic PLUS refers to four considerations that apply to the analysis in steps 1, 4 and 7 of the decision-making model as follows.

P = Policies
L = Legal
U = Universal
S = Self

A description of each filter and its role in decision-making follows (Ethics Resource Center of the Ethics & Compliance Initiative, The PLUS Decision Making Model, https://www.ethics.org/resources/free-toolkit/decision-making-model/).

Policies. Is it consistent with organizational policies, procedures and guidelines?
Legal. Is it acceptable under applicable laws and regulations?
Universal. Does it conform to universal principles and the values of the organization?
Self. Does it satisfy my personal definition of right, good and fair?

The advantage of the PLUS model is it relies heavily on organizational ethics. This is important because no matter how good one’s ethical judgment may be, ethical decision-making is not likely to occur unless support for the position exists in the organization. A summary of the seven-step model follows.

Step 1: Define the problem. Determine why a decision is necessary and identify the desired outcome(s). This helps to clearly state the problem and where to look for alternatives to resolve it. Consider the PLUS factors to ensure the existing situation does not violate any of them.

Step 2: Seek out relevant assistance, guidance and support. Identify the available resources within the organization to help resolve the problem. This helps to define the guidelines and individuals within the organization that may help to resolve the problem.

Step 3: Identify available alternative solutions to the problem. Consider all relevant solutions to avoid the dichotomy of one choice versus another (i.e., either this or that).

Step 4: Evaluate the identified alternatives. This step in the model uses a decidedly consequence-based criteria. Positive and negative consequences are evaluated with fact-based consequences weighed more heavily because the expected outcome is more likely to occur. The PLUS factors are an integral part of the evaluation to supplement outcomes-oriented considerations, which are teleologically based, with universal principles (deontology) and virtue ethics as represented by organizational values.

Step 5. Make the decision. After evaluating all the alternatives, it’s time to decide on a course of action. The reasons for choosing one alternative over the others should be explained especially if the decision is by a work team that recommends a solution to higher-ups.

Step 6. Implement the decision. Putting the decision into effect is essential to change the situation and resolve the problem identified.

Step 7. Evaluate the decision. A determination has to be made whether the decision fixes the problem identified. Questions to ask are: Did it go away? Did it change appreciably? Is it better now, or worse, or the same? What new problems did the solution create? In making these determinations it’s important to incorporate the PLUS factors to ensure the solution conforms to organizational policies, laws and regulations, universal principles and values adopted by the organization.

Advantages of the PLUS Model

The “S” component of the PLUS factor is a feature of the decision-making process that requires explanation because it’s not recognized explicitly in traditional decision-making models although virtue considerations come close. To implement the “self” factor, the decision maker should consider whether the solution satisfies one’s personal definition of right, good and fair. It means that individuals should understand how their values influence decision making to ensure the decision reflects those values. For ethical decision-making to occur in an accounting situation those values should include independence, integrity, objectivity and due care, which are the principles of professional behavior.

Ethical decision making is a complicated process that relies on organizational variables to ensure the ultimate decision is supported by those who have to carry it out. The PLUS model incorporates those factors and should be used in accounting ethics education to make it more relevant given the increased focus on organizational ethics in the post Sarbanes-Oxley era.

The advantage of using the PLUS model to teach ethics to accounting students is it increases student awareness of organizational factors that influence ethical decision making. In reality, regardless of the ethical justification for one’s position it’s unlikely to be implemented unless individuals within the organization support resolution of the ethical problem. Knowing how the internal systems work can help to make that determination early on and influence ethical decision making in a positive way.

Sustainability Reports and the Limitations of ‘Limited’ Assurance

Editorial Note: We are delighted to publish the following article by Professor Michael Kraten of Houston Baptist University. It was originally published in this month’s issue of The CPA Journal; we thank Journal Editor-In-Chief Rick Kravitz (who is himself a frequent contributor to our blog) for permitting us to transmit the article to our Section members. We encourage our members to peruse the contents of this month’s issue at CPAJournal.com.

How many standards can a sustainability accountant possibly follow? Three dozen comprehensive standards are published by the Global Reporting Initiative (GRI), and 77 industry-specific standards are issued by the Sustainability Accounting Standards Board (SASB). In addition, 17 sets of metrics are promulgated within the Sustainability Development Goals (SDG) of the United Nations, 15 components of integrated reporting are defined by the International Integrated Reporting Council (IIRC), and the AICPA, not to be outdone, chimed in earlier this year with its new guide, Attestation Engagements on Sustainability Information.

Sustainability standards are growing in length and complexity; as a result, the length and complexity of corporate sustainability reports are growing as well. The 2018 sustainability report of Volkswagen (VW), for instance, runs at 108 pages. The report of its European rival Fiat Chrysler Automobiles (FCA) is much lengthier, at 148 pages.

Some analysts complain that such reports are filled with “green-washed” public relations content. Others disagree, claiming that the European Union’s Directive on nonfinancial reporting ensures that the sustainability content is meaningful on an individual report basis and comparable across multiple reports.

To be fair, the latter group of analysts can cite examples of meaningful and comparable data. VW’s report, for instance, includes a section entitled “GRI Content Index”; it cross-references its published data to the standards of the Global Reporting Initiative. FCA’s equivalent section, the “GRI Standards Content Index,” serves the same purpose.

But are readers of sustainability reports missing out if they only pay attention to the sustainability report data and the underlying standards? Should they also pay attention to the assurance letters issued by public accounting firms and printed in the reports? After all, if the assurance letters are not sufficient, then all of the information in the reports, greenwashed or substantive, is of dubious value.

Consider, in comparison, the annual financial statements of business entities. They would obviously be less useful if public accounting firms were to use extremely limited assurance procedures during their annual audits. Their assurance procedures would be even less useful if auditing firms could offer different levels of assurance to different clients.

Indeed, spending a little less time worrying about the data in the sustainability reports and a bit more time considering the limited assurance letters may lead to the conclusion that confidence in the validity of any of the report data may not be warranted.

Volkswagen

Consider, for instance, Volkswagen’s 2018 report. The table of contents lists a two-page “Independent Assurance Report” on pages 104 and 105. That assurance letter, issued by PricewaterhouseCoopers, is called “Independent Practitioner’s Report On A Limited Assurance Engagement On Non-Financial Reporting.” How much assurance does it actually convey?

The letter notes that PricewaterhouseCoopers is required to “plan and perform the assurance engagement to allow us [i.e., the CPA] to conclude with limited assurance that nothing has come to our attention that causes us to believe that the Company’s Non-financial Report … has not been prepared, in all material aspects, in accordance with” the relevant standards.”

This double-negative structure raises some flags. In essence, the CPA is only required to conclude that nothing came to his attention to cause a belief that something is not right. Metaphorically speaking, an ostrich that buries its head in the sand during a desert storm could satisfy that level of assurance about the weather.

The letter continues by listing eight assurance procedures that were performed by the CPA. It notes that PricewaterhouseCoopers obtained an understanding of the structure of the organization, conducted inquiries regarding the preparation process, analytically evaluated selected disclosures, compared selected disclosures, and so on. There are, however, almost no detailed disclosures of the nature of the inquiries that were made, the disclosures that were selected for analytical evaluation or comparison, or anything else. Interestingly, PricewaterhouseCoopers does list a single specific procedure in its letter; it notes that it performed an “assessment of the aggregation of Scope-3-GHG-emissions (categories 1 and 11) on group level.” That procedure may have been necessitated by Volkswagen’s recent global emissions scandal. (For more on the Volkswagen case, see “The Volkswagen Diesel Emissions Scandal and Accountability” by Daniel Jacobs and Lawrence P. Kalbers, on p. 16 of this issue.). Nevertheless, no other detailed procedure is disclosed in the report.

Finally, the letter concludes with a disclaimer that it “is not intended for any third parties to base any (financial) decision thereon. Our responsibility lies only with the Company. We do not assume any responsibility towards third parties.” Thus, PricewaterhouseCoopers’s letter is not designed to serve the needs of the readers of Volkswagen’s sustainability report, despite being the sole assurance letter that is included in that very report.

Incidentally, although Volkswagen’s 2017 sustainability report is comparable to its 2018 report, one cannot compare these two documents to its 2016 report. Although a synopsis of the 2016 report is posted online, the full 2016 report has been deleted from the Internet. It is left to readers to wonder what was in the full report and why it is no longer available.

Fiat Chrysler Automobiles (FCA)

Fiat Chrysler Automobiles’ table of contents likewise lists a two-page “Independent Auditor’s Report” on pages 139 and 140. That letter, issued by Deloitte, is called “Independent Auditor’s Report on the Sustainability Report.” Deloitte does not explain why it refers to itself as an auditor and not as a practitioner (as PricewaterhouseCoopers does).

Furthermore, Deloitte’s letter contains the same double negative language as PwC’s, concluding that “nothing has come to our attention that causes us to believe that the Sustainability Report … is not prepared, in all material aspects, in accordance with” the relevant standards.

The Deloitte letter lists seven bullet points of assurance procedures. Certain details are excluded from the Deloitte report but are included in the PricewaterhouseCoopers report, and vice versa. For example, PwC’s explicit statement about its GHG emissions assessment procedure is missing from Deloitte’s letter. Conversely, Deloitte’s letter explicitly refers to analyses performed on “minutes of the meetings,” and the receipt of a “representation letter signed by the legal representative” of Fiat Chrysler. Such language is missing from the PricewaterhouseCoopers letter.

Finally, Deloitte’s letter does not contain a warning that it “is not intended for any third parties to base any decision thereon,” or that Deloitte does “not assume any responsibility towards third parties.” PricewaterhouseCoopers’s letter, as noted above, includes these disclaimers.

The Limitations of Limited Assurance

Should stakeholders worry about these facts? On the one hand, it is important to keep in mind that the sustainability movement has succeeded in compelling global corporations to issue more than 100 pages of data each year. Even if significant portions of the reports are filled with green-washed information, the remaining (and perhaps some significant) portions of the reports may contain useful data.

On the other hand, it is also important to keep in mind that the limited assurance of these public accountant’s sustainability letters provides, in certain respects, even less assurance than detailed agreed-upon procedure letters. After all, an agreed-upon procedure letter contains detailed descriptions of the procedures that are performed and the findings that are produced by the procedures. In contrast, the limited assurance letters in these sustainability reports contain very little detailed information and only reach vague, double-negative conclusions regarding the findings.

Furthermore, the descriptions of the procedures in the letters are inconsistent from company to company, and the disclaimers regarding the use of the letters by third parties vary remarkably from firm to firm. Such inconsistencies and variations greatly reduce the value of the assurance reports, and thus of the sustainability data that are included in them.

Clearly, there are significant limitations to the limited assurance letters in the sustainability reports. Perhaps, in addition to lobbying for improvements in sustainability reporting standards, public interest advocates should consider lobbying for the development of more stringent sustainability assurance standards.

Accounting In The Food And Drink Industry

Editorial Note: We are delighted to publish the following editorial by Professor Lisa Jack of the University of Portsmouth in the United Kingdom. The content is representative of the quality of the material that our colleagues will share at our 2019 Annual Meeting in San Francisco next month.

We hope to see you there! As always, when you read the comments of our columnists, please keep in mind that they only speak for themselves. They are not expressing the positions of the AAA or of any other party.

Is it in the public interest to know about accounting in the food and drink industry? As one of the very few researchers in the discipline who study this field in depth, and I’ve been looking at the industry for nearly 20 years now, what I usually encounter is a vague idea that accounting in the area ‘cannot be that complicated’, something that runs philosophically with a general unawareness of what really goes into producing food and drink in a developed, capitalist country.

It’s not that people are generally disinterested in food and drink, and where it comes from. Yes, some schoolchildren and some adults take supermarket food for granted and are bemused to find that what they eat involves animals and plants (and chemicals). But the TV schedules, in the UK and Canada at least, are filled with people cooking and baking, and investigating ‘how things are made’, food scandals, diets and advising on how to reduce the costs of the weekly shop for families. Gastronomy, artisan foods, organic, vegan – all are taking new footholds and as Julie Guthman of UC Santa Barbara says very quickly become part of a capitalism that embodies (literally) the faults in the system. The domination of capitalist multi-retailers and food processing companies is directly implicated in policy on both obesity and healthy eating.

In fact, most of us have a reasonable general knowledge of food and some perception of what it costs to produce, distribute and sell. But it is a complicated industry, with complicated social interactions at play. The accounting is also complicated – and often under the radar. So, I want to touch first on how others have articulated the underlying problems and then on bringing forward some of the things I’ve found going on under that radar. In particular, here, I’m interested with others on how city dwellers (around 55% of the world’s population according to the UN, and set to rise to 68% by 2050) see food.

Michael Pollen (The Omnivore’s Dilemma) and Michael Carolan (The Real Cost of Cheap Food) are the other must reads in this area, along with Julie Guthman (Weighing In).

One of the most quoted and respected writers in the US is Wendell Berry (b.1934), this is an extract from ‘The Pleasures of Eating’.

I begin with the proposition that eating is an agricultural act. Eating ends the annual drama of the food economy that begins with planting and birth. Most eaters, however, are no longer aware that this is true. They think of food as an agricultural product, perhaps, but they do not think of themselves as participants in agriculture. They think of themselves as “consumers.” If they think beyond that, they recognize that they are passive consumers. They buy what they want — or what they have been persuaded to want — within the limits of what they can get. They pay, mostly without protest, what they are charged. And they mostly ignore certain critical questions about the quality and the cost of what they are sold: How fresh is it? How pure or clean is it, how free of dangerous chemicals? How far was it transported, and what did transportation add to the cost? How much did manufacturing or packaging or advertising add to the cost? When the food product has been manufactured or “processed” or “precooked,” how has that affected its quality or price or nutritional value?

Georg Simmel wrote in 1903 in ‘The metropolis and mental life’: “…the money economy that dominates the metropolis in which the last remnants of domestic production and direct barter of goods have been eradicated and in which the amount of production on direct personal order is reduced daily. Furthermore, [a] psychological intellectualist attitude and the economy are in such close integration that no-one is able to say whether it is the former that has affected the latter or vice-versa”. One result might be that living in a city makes one unaware of the cost of food production, and the effects of a demand for cheap food on suppliers and producers. The English writer Adrian Bell (1931) says that when he was a struggling farmer (having been a city-bred boy who chose an apprenticeship on a farm over other professions): “I began to realise, also, how much of the money which the consumer says he gives so plentifully, and of which the producer says he receives so sparingly, fell through the hole in the middle-man’s pocket into the gulf of wastage and wear-and-tear. What Mrs. Sinks of Surbiton doesn’t realise is that for the privilege of going out at any moment and buying a chicken ready for the oven, she has to pay for all those other times when the chicken was waiting for her and she doesn’t want it”.

This last quote is so relevant to what I hear in conversations that I have today. Consumers (or “individual eaters” for a less pejorative term these days) tell me at length either about how wicked it is that the supermarkets charge so much and make such large profits, or at length about how they are prepared to pay more in order to get quality, or fairness, or whatever, and how wicked it is that supermarkets charge so little for (junk) food. Producers, suppliers and retailers tell me about the difficulties of maintaining incredibly tight NET margins averaging around 1-2% of turnover, but I also find that increasingly, I am looking at the money that vanishes in between. I am also taken with looking, as Bell does, at the problem from the other side, the non-consumer side. Here in the UK, for example, food manufacturing, processing, distribution and selling accounts for some 29.5% of GDP, employs 14% of the workforce and accounts for £22bn of exports (including quite a lot of scotch whiskey). Yet, of the 6,000 companies in the industry (excluding farmers, around 2% of national production), 5,800 are small or mid-sized entities and nearly 1500 are teetering on the edge of insolvency.

What is included then, in a conversation about accounting and the public interest? A surprising number of topics, in fact, which include: subsidies and support from government; the public cost of deleterious consequences of the food industry – public in terms of social and environmental damage; individual costs in terms of health and well-being; pay inequality (there are attested reports of workers in supermarkets having to use foodbanks, whilst executives can be very highly remunerated); the whole cheap food debate linked to the real costs of production; power and capitalism, evinced in the extreme concentration of production and selling in the hands of a few businesses. These debates are already out there but I promised to discuss what things go under the radar, which is what I research. Here are three of them: commercial income; discounting in negotiations and the growth of food service. There is also the nature of narrow margins, marginal costing, performance measurement and risk assessment and their effect on the fairness of the industry*. Enough for a book, let alone one blog post, so I am just going to focus in on commercial income.

In the UK, the largest supermarket (Tesco) was acquitted on charges of fraud related to an overstatement of £250million in its profits. What is not in dispute is that the overstatement related to recognising commercial income in advance.

Following disquiet on its commercial income, the supermarket Morrisons in the UK started to lead the industry on disclosures of this activity in the annual report but only from 2014/15. The Germany-based discounter, Aldi (recently spotted in an outpost in Ames, Iowa and a significant rising player in the UK), states clearly that it does not use commercial income in its purchases.

In the US, as one BBC article reports, “According to Fitch, the credit rating agency, the payments are the equivalent to 8% of the cost of goods sold for the retailers, equal to virtually all their profit.”

So, what is commercial income? Briefly, it is income from suppliers to retailers. This, of course, should elicit the response ‘What, hang on a minute, customers pay suppliers, right, not the other way around?’ This is to fundamentally misunderstand the nature of multiple retailers (supermarkets). In fact, the new terminology handily loses the term ‘market’ but that is what they are offering and managing. Like a marketplace, you pay the market owner for a place and their ability to bring people in to buy. You might reward them for doing the latter well and for selling large quantities of your product. Commercial income, then, includes a raft of payments extracted from the supplier for the privilege of supplying – space, bonuses, discounts offered and so on. However, supermarkets are also now driven by customer demand (created largely by the supermarkets themselves) for full shelves, full choice all year around. Suppliers tied into the system, already taking the slimmest of margins for their products because the margin needed by the retailer to run their system is substantial, are bound to deliver in full, to specification, on time. For some supermarkets, the slightest infringement of this incurs penalties, also accounted for under ‘commercial income’. The supplier might well lose the payment for the consignment as well. An article in the British weekly industry publication in 2015, ‘The Grocer’ lists around 30 different types of commercial income.

Essentially, supermarket profits do not come from consumers, they come from suppliers. Link that with extended payment terms and it becomes clear why small and mid-size food companies, and their employees, are at risk. It is not a case of ‘supermarkets bad, suppliers/consumers good’. There are retailers have records of working to build long-term beneficial relationships with some suppliers and many consumers themselves prefer to shop under the radar than visibly in a local shop, and to have the perceived convenience. The job for accounting researchers is to help devise possible alternatives to enhancing profits that do not involve commercial income, low wages and non-affordable food. That really is a research challenge.

Pay Your Dues and Get Abuse

Editorial Note: We are delighted to publish the following editorial by Paul F. Williams, the 2013 recipient of the Accounting Exemplar Award. The content is representative of the quality of the material that our colleagues will share at our 2019 Midyear Meeting in Orlando next week.

We hope to see you there! As always, when you read the comments of our columnists, please keep in mind that they only speak for themselves. They are not expressing the positions of the AAA or of any other party.

***

Paul F. Williams is a Professor of Accounting at the Poole College of Management at North Carolina State University. Paul earned a BSF from West Virginia University, and MBA and Ph.D. degrees from the University of North Carolina at Chapel Hill. He joined the N.C. State faculty in 1985 after spending 1977 to 1985 at Florida State University. His research interests include accounting ethics, theory, and critical perspectives in accounting. His publications have appeared in Critical Perspectives on Accounting, Accounting, Organizations and Society, The Accounting Review, Contemporary Accounting Research, Journal of Business Ethics, Accounting and the Public Interest, Accounting Horizons (for which he won the best paper award for 2014), among many other journals. He has served as chairperson of the Public Interest Section of the American Accounting Association and as editor of Accounting and the Public Interest. He received the Public Interest Section’s Accounting Exemplar Award in 2013.

An astonishing event occurred at the 2016 Centennial meeting of the American Accounting Association (AAA). Even more astonishing is that the event went largely unremarked – it passed into history without disrupting the normal life of the North American accounting academy. That it might not be obvious to many of you who happen to read this blog to what I am referring proves my point. It also says something about AAA leadership and even more about AAA members. What it says about us as members of AAA is not encouraging. The event to which I refer is the Plenary devoted to the proposition that accounting will be a learned profession by the year 2036. That obviously means, at least in the opinion of the AAA leadership, accounting is not as yet a learned profession. The astonishing part of the public admission that accounting is as yet not a learned profession is that a characteristic of professions is that they are, by definition, learned. There cannot be an un-learned profession. Would the legal profession or the medical profession ever publicly admit they were not yet learned? A lot more to learn, yes, but not as yet learned? We should be embarrassed by such an admission since we have already had over a century to become learned.

That law or medicine (or any other academic discipline) would admit to such a thing is not likely. This is so for at least two reasons: 1. Something is being learned by someone in order to be admitted to the discipline and that something is substantial and continuously tested with some process for ascertaining the value of that something, and 2. There is not a monolithic organization that controls the process by which something enters the canon of what is permissible learning and what is not. Unlike medicine and law where research and practice are intertwined, the accounting academy in the U.S. is unusual in that the something to be learned to be admitted to the practice of accounting is determined largely by the rules promulgated by regulatory bodies (e.g. FASB, IRS, SEC, PCAOB, etc.). Perhaps only second to the military is any field so dominated by acronyms as accounting – acronyms that stand for organized bodies writing rules. The academy produces very little that actually makes its way into the canon which must be learned to be admitted to the profession (it does however contribute a great deal to what must be believed). Given the academy’s lengthy disinterest in the actual practice of accounting or the actual function of accounting in society, a promise to make accounting a learned profession seems a bit disingenuous.*

Law, medicine, or almost any other scholarly discipline is dispersed. There are vast numbers of people engaged in those disciplines without extensive centralized bureaucratic control. The natural sciences which provide us lay people with the template for the so-called scientific method could not function as sciences under bureaucratic control (the Lysenko affair in the old USSR is a case in point). Freedom to explore is essential to “progress.” There are no single organizations that legislate the structures or contents of scientific disciplines. For example, according to Hossenfelder (2018, p. 153) there were 2,000 physics PhDs awarded in the U.S. in 2012. Membership in the American Physical Society is 51,000 and the membership in the German Physical Society is 60,000. The sheer number and dispersion of people doing physics provides at least a freedom from control by anything other than the constrictions of the discipline itself, i.e., there are certain things you are no longer permitted to believe since they have been ruled out as believable by the discipline, not by an organization that controls the discipline through bureaucratic fiat.

Accounting, at least in North America, is, perhaps uniquely, a discipline where discipline is imposed by a bureaucratic organization. Accounting as an academic discipline is extraordinarily small compared to virtually all other academic disciplines. As the physics example illustrates fields in the natural sciences are populated by thousands of people. Accounting academics are relatively few in number and emerged as such largely in the U.S. Prior to the movement to make business disciplines more scientific, which began in the 1950s, accounting was taught mostly by people from practice and research in the sense of applying the methods of social science was non-existent. What shape a scientific approach to accounting would take was contested territory. The first quantitative applications in accounting appeared in the area of management. The developments in operations research that came about because of WWII appeared in TAR written by people like W.W. Cooper. Edwin Caplin was an early pioneer in introducing psychology to the investigation of accounting – thus was born behavioral accounting research. But the battle for hegemony over the accounting research agenda has clearly been won by the group that claims ownership of the financial reporting revolution. This is a clearly identifiable group of cohorts who matriculated at the University of Chicago between the mid-1960s and the early 1970s. Their significance is evidenced by the fact that the first four Seminal Contributions to the Accounting Literature Awards were given to work produced by that cohort. Apparently nothing of any intellectual value was produced prior to this group of persons steeped in neoclassical economics Friedman style and neoliberal ideology (Friedman was a founding member of the Mt. Pelerin Society).

Because there is a monolithic organization (the AAA) that manages the U.S. professoriate control of the AAA gives control of the agenda. The Seminal Contribution Awards** is a case in point. Perhaps some of you know how the selection process for that award works, but I don’t. Magically it is announced that one has been bestowed, but who does it or how it is done is a mystery. The AAA has a history of self-appointed elites as the laughable case of ARIA (Edwards, et al., 2013) illustrates. The doctoral consortium and the new faculty consortium were created as mechanisms for controlling the agenda. I attended one of the early doctoral consortia in 1974 and the entire program was dedicated to EMH and the methods of financial economics. A most vivid memory of that experience was the panel on which Sandy Burton was invited to speak only to be assaulted for his naïve understanding of the world by rebel soldiers in the financial reporting revolution. Some years later Gary Previts made an effort to introduce doctoral students to broader perspectives and had Tim Fogarty organize a faculty that included a Foucaldian, a leading accounting historian, a past editor of Issues in Accounting Education, an eclectic scholar, and an ethicist. Needless to say the reaction by the AAA’s director of research was one of extreme displeasure and none of those people were ever invited back.

The proclivity of the AAA toward bureaucratic control of the discipline is perhaps understandable. It is, after all, an organization populated mostly by people who lived in the culture of the accounting profession, a culture that places highest value on conformity. To me the latest outrage is the change in procedure for the selection of the best paper awards for Issues and Horizons. In spite of the changes in bylaws made a few years ago, there is no visible effect of those changes on the intellectual agenda of the AAA becoming more diverse. Horizons and Issues were created to devalue certain scholarship. TAR used to contain an Education section, but it was removed because rewarding someone with a TAR citation for writing about education was just not on. Comments were eliminated from TAR as well because a TAR byline could not be provided to someone who just wanted to comment, particularly if the comment cast skepticism on the content of TAR. Horizons was to be where articles that could be comprehended by practitioners were to be published, but it quickly became a paler version of TAR. Since articles in Issues and Horizons were not deemed serious scholarship the best paper awards for those two journals were left to a plebiscite of the members. The winners of the Horizons awards reflected the eclectic interests of the members. Papers dealing with education, systems, audit, history, epistemology, sociology of knowledge, and, yes, financial reporting were winners. This past year, however, the idea of letting the members choose from among all papers published in Horizons, was apparently deemed too risky. The AAA decided that might lead to the “wrong” kind of literature being noted as award winning. So the list of acceptable papers was pared to only five, all of which dealt with financial reporting. What little power the members have to shape what the AAA acknowledges as intellectually worthy has been taken away and without a whimper.

The people who gave us the financial reporting revolution and their successors have for some years now been expressing angst over the stagnant, banal nature of accounting research. As far back as 1991 a group of pre-eminent revolutionaries remarked on the lack of creativity in accounting research (Demski, et al. 1991). Judy Rayburn’s AAA presidency made central the issue of the lack of diversity in accounting research; she invited Anthony Hopwood (noted for Accounting from the Outside) to be her Presidential Speaker. Shyam Sunder made the theme of his presidency Imagining New Accountings and Greg Waymire pushed for Seeds of Innovation while proclaiming, “I believe our discipline is evolving towards irrelevance within the academy and the broader society with the ultimate result being intellectual irrelevance and eventually extinction” (Waymire, 2011, p. 3). But like the monkey with its fist inside the coconut shell, the leadership is incapable of relinquishing their ideological control over the nature of accounting as an intellectual discipline. Accounting research isn’t evolving toward irrelevance; it’s been irrelevant for quite some time. In spite of lip service to Imagining and Innovation, the management style of the AAA is to stifle Imagination and Innovation because that threatens the ideology and the associated reward structure that the financial reporting revolutionaries established nearly 50 years ago and from which they have so richly rewarded themselves. Virtually every North American doctoral program produces the same standardized education designed primarily to enable students to meet the standards of the so-called premier journals, which the revolutionaries also created. The accounting proclivity to standardize everything, even things we don’t understand well enough to standardize, has given us GASS (Generally Accepted Scientific Standards). I admit to being guilty of subsidizing through the dues I have paid this incoherent circumstance of needing more creativity in the academic process but allowing that process to be managed by an organization that has repeatedly demonstrated its inability to cede its autocratic instincts. I have been waiting for decades for our “I’m as mad as hell and I’m not going to take in anymore,” moment. It appears it will never come.

* The history of accounting academia post WWII with its fixation on price level effects and income theories, the creation of JAR and its positivist ideology, and the information metaphor itself stem from intellectual contempt for the premises of accountants in the field. With the exception of Ijiri, the academy abandoned a long time ago the discourses that informed practice because they were intellectually inferior to those of neoclassical economics.

** “Seminal” is apropos since all of the winners so far have been men.

Are Annual Audits still “Fit for Purpose?”

Editorial Note: We are delighted to present the following editorial column by Nick Shepherd, President of EduVision. Nick currently chairs the CPA Canada Committee for developing Statements in Management Accounting.

As always, when you read the comments of our columnists, please keep in mind that they only speak for themselves. They are not expressing the positions of the AAA or of any other party.

Annual reports together with various supplementary requirements and filings are important for boards, investors, rating agencies and others as a foundation to assess and determine the financial health of an organization. Historically this has worked reasonably well; up until the 1970’s most of the corporate value – an average of 80% – was reflected on the balance sheet. If the audit revealed the integrity of assets and liabilities, there was a reasonable expectation that the business was healthy.

Fast forward to today. Most corporate value for owners, investors and others is now intangible with only an average of 15% represented by financial assets. While certain intangibles can be capitalized and included on the balance sheet, the majority are nowhere to be seen, nor are they assessed or reported on through the audit. If an audit is designed to provide reasonable assurance of organizational health and integrity, doesn’t basing this on the verification of only 15% of the value seem high risk?

There is continuing criticism of auditors and the profession for failing to alert investors and others to potential risk when organizations fail – yet how can the profession shoulder the blame when its scope and mandate are determined by compliance with standards that focus principally on tangible assets and liabilities? Apparent failures in oversight and governance approaches are not attributable to the profession alone, but the profession does have a responsibility to reflect on its own role and determine whether the principles that were initially established for audits are still meeting their goals. When significant “sea change” occurs, it requires re-invention rather than improvement. Is society changing the expectations and rules that make an audit relevant? Or are we “re-arranging the deck chairs on the Titanic?”

Customers of the audit profession are increasingly asking for additional information to enhance their risk assessments; this has resulted in regulatory changes as well as voluntary supplemental reporting. In certain jurisdictions, certain supplemental reporting – such as environmental and social issues – are now mandatory. A major thrust is being implemented by those adopting “integrated reporting,” but in most cases, this is not mandatory, audited or based on strongly established standards. A “sea change” it is not! The financial profession does not appear to be front and centre in driving fundamental change, apparently believing that its focus on financial capital remains adequate. Yes, changes are being made, but progress is much too slow; thus, the risk of “surprises” continues to increase.

The profession must start asking some fundamental questions in order to drive governance and accountability changes so that audits are fit for purpose. As a start, let’s consider the drivers of sustainable corporate value creation, and try to “peel back” corporate performance in the areas that might give investors an increased visibility into risk.

From a financial perspective, two sources of cash flow are critical to a sustainable business. First, for most organizations, more than 60% of expenditures are driven by employee costs; yet employee productivity and effectiveness are hard to measure, other than at the macro level. However, we do know that most employee costs are traditionally considered period expenses that convert inputs to outputs.

This is no longer the case, with large portions of employee expense related to building “capacity,” i.e. the contribution of intellectual capital that provides history and process capacity, as well as innovation in process improvement, new products and services, and relationship building with third parties. Only “motivated” employees will do this continually and effectively. To be a sustainable business in the future, the audit should reveal:

    • The overall level of expense committed to employee costs, with a split showing (hopefully) a declining share going into repetitive conversion costs, and a growing share committed to building “intangibles for the future.” Key indicators might also include “strategic reassignments” that give perspectives on whether management is committed to redeploying staff as a result of change versus firing them (which does not create motivation).
    • Levels of employee engagement at a depth of detail that is more than just a general percentage. What is needed is visibility into alignments of individuals, teams and departments with organizational purpose, both in “task” (the work of the business) and also critically in behavior (the stated conduct of the business that is driven by its culture and its understanding of ethical compliance).
    • Leadership effectiveness. Disengagement comes from a gap between what organizations state they do, versus what employees see from leaders. The effective development of internal leadership, accompanied by the results of 360° assessments based on corporate values, would start to identify areas of concern if they exist. It might have been interesting to see what indicators of this type would have shown for some of the banks involved in recent scandals.
    • Focus on “behavioral based” internal controls. Process controls are no longer adequate in an environment where high levels of delegation take place, leading to individual autonomy (this also applies to controls and relationships with third parties. such as outsourcing providers). Stronger reporting is needed on ethical hiring, leadership values and behavior, whistle blowing, levels of employee stress, illness (especially mentally related issues), and other behavioral aspects.

Overall, what users need to know is whether approaches to the workforce are protecting human capital sustainability through effective nurturing and development of people.

The second core cash flow is “cash flow in from customers.” Areas such as retention rates, repurchasing patterns, repeat customers and others are all important, but especially critical are relationships. One factor that could be more fully implemented into annual reporting is the stability of brand value.

The attached table shows 2018 data regarding the year end and most recent brand valuations by either Interbrand or Brand Finance (we used the higher valuation). This table demonstrates that, although the “pure audit” of financials provides insight into book values (i.e. balance sheet / shareholder equity), the shareholders value of their investment (i.e. the market value) is much greater.

Several key questions should be of interest to the investor. Using the traditional audit, is the integrity of the balance sheet acceptable? Is the brand value, as calculated by independent third parties, increasing or decreasing? If so, why? And what is the impact on this for the future? For instance, was a potential “auditable” cause the diversion of human capital resources away from customer support activities to enhance financial capital results? Finally, what makes up the ‘other intangible assets’ that contribute a key part of an investment valuation, but that are not being assessed or audited?”

One key failure of the accounting profession is to grasp and modernize the assessment of goodwill. On a sale or purchase of a business entity, it is the “market value-based intangibles” that end up on the acquirer’s balance sheet that must be assessed for “impairment.” How can an auditor do this effectively if the drivers of this value have not been clearly determined?

As can be seen from the table, book values range from 5.9% of value to 24.4%, and it is these underlying valuations of “financial capital” that a traditional audit discloses. If these are examples of the impact on financial capital of the growing knowledge economy, then one can only conclude that audits that remain focused on financial capital alone are not “fit for purpose.”