Accuracy, Timeliness, and Managers’ Discretion of Fair Value Pricing: Evidence From the Banking Industry

Abstract

This paper investigates how recent institutional developments impact the potential channels, and thus available discretion, by which managers can manipulate reported fair values. First, I use extensive field research to document the mechanisms used by banks to procure and report fair values—particularly incorporating the impact of the 2011 FINRA’s Trade Reporting and Compliance Engine (TRACE), and concurrent increase in independent third-party vendors. Key insights include that (i) banks predominantly apply third-party vendors’ feeds to generate financial statements (with nearly 100% of vendors’ feeds passing automatically to reported financial statements, with only rare adjustments); and (ii) external auditors predominantly relying on different vendors’ prices to verify and challenge banks’ inputs. Second, I employ three proprietary datasets of daily financial-instrument level pricing—capturing both TRACE and third-party vendors—to document the following insights. I find that vendors’ evaluated prices dominate historical costs in all performance metrics, confirming they provide a more accurate, objective, and reliable proxy for fair value than historical cost. I also find that vendors’ fair values are value-relevant and account for 90% of the trade-to-trade price variance, creating an upper bound on managerial discretion (of only 15% of the original level). Finally, I find that bank managers respond to these newly imposed constraints by alternatively engaging in more spoofing-transaction based fair value manipulations: suggesting this is a likely (even primary) channel by which manipulation can be attained. Overall, the evidence suggests that fair values, particularly after the above institutional developments, appear less subjective, less costly to implement, and more convenient for auditors to verify and challenge, than the literature has previously reported.