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[dialogue]

A perspective on accounting form of government, free-enterprise fail; apparently this is not going to
I appreciate very much your system and high standard of living. All take place. The sound and principled
thoughts and editorial regarding mark U.S. citizens have a higher standard policy is obvious. Limit the size so that
to market accounting (Straight Talk, of living than 90 percent of the rest they cannot dominate the government.
Jan. 1, 2009). I taught Principles of of the world. A significant number of (A consistent banking rule - do not
Accounting at the Wharton School so people want to come here to live. This have a borrower so big he controls
I have some feeling for the accounting gigantic increase in the national debt the bank.)
function. will encumber the country and likely The American Bankers Associa-
And I think our esteemed friend, decrease the value of the dollar. tion and the Independent Community
Mark Olson [chairman of the Puh- Many economists perceive TBTF Bankers of America should stand on
lic Company Accounting Oversight as bad economics. It rewards bad principle; introduce and lobby for a
Board], has forgotten what it is like management, discourages good man- law (in banking where they have the
to run a bank. agement, increases moral risk, and if expertise) where no bank could be
Years ago, the function of account- not stopped, will be an unsustainable allowed to have so many assets that
ing was to present factual, verifiable, drain on the Treasury. There has its demise would pose a risk to the
data on asset and expense costs, been a lot of comment on the dangers, country. One percent of total national
income received in accrual, dollar risks, unintended consequences and deposits might be okay, if that is not
amounts of liabilities, etc. Opinions, economic idiocy. (See Gary Stern's too high. Return to the states their
judgments, market values were limit- "Top of the Ninth" column in the Sept. right to oversee the financial institu-
ed primarily to current assets - invest- 2008 edition of The Region published tions in their own state.
ments, receivables - and depreciation by the Federal Reserve Bank of Min- Some give the excuse (because they
and valuation reserves. neapolis.) do not want to take the high road) that
Then the Big 4, 5 or 8 decided that TBTF is not a good policy and you cannot put the genie back in the
they wanted to be financial consul- should go the way of the dodo bird. bottle. (Who let it out?) Look at Teddy
tants as well until Washington put But, even those opposed when faced Roosevelt, he limited trusts.
the kibosh on that. So now FASB has with the prospect of failing a TBTF Maybe it will be an uphill battle
found another way to create make- will, in effect, say "yes but not on my against the megabanks and their
work, non-cost-effective accounting watch." The solution to this malady is lobbyists. But, if it is better for the
requirements, which they think look to limit and reduce the size of TBTF country and the economy, it is never
good in their ivory tower, but which institutions that pose a systemic risk. wrong to stand on principle.
cost banks millions of dollars in pa- Stop the tail from wagging the dog. Either ABA or ICBA will take some
perwork and fuss. The Fed has studies that show similar position or will do nothing,
I respect former regulators William economy of scale is mostly illusionary; which is a position saying let the risk
Isaac and Eugene Ludwig who feel the primary beneficiary is often the grow. We all know there will be a push
that there still is a place for regula- executives. One might compare them to raise the limit that will make banks
tory accounting, not just GAAP. And to a farmer who wants to expand, not even more TBTF. This is not a solution;
why can't the market information, much, just the land that adjoins his. it is suicide.
which FASB wishes be disclosed, be No matter what the limit, there will Next, some wild D.C. planner will
done in the footnotes for the analysts always be pressure for more. want to revive the Townsend Plan of
to use?! For the good of the country, the the 1930s.
obvious axiom is to limit the size of Either stand on principle or say you
B. P. Allen, Jr., Chairman any and all entities whose failure will will not; in spite of the song, there is
First National Bank, Milaca, Minn. place a systemic risk on the entire no "Mr. In Between!"
country. (In a free society, there will
Bailouts and 'Too Big To Fail' always be some business failures.) John Dean, Chairman I CEO
TBTF started with Continental The direction we are headed in is Glenwood State Bank
(mistake) and has been expanded and calamitous. Soundness would let them Glenwood, Iowa
expanded to where we are now: any-
thing, anywhere and anytime. We are
on a slippery slope, an avalanche to-
ward actual or de facto nationalization Do you have an opinion you'd iike to siiare?
of banks and who knows what else.
The cost to Treasury (citizens) We're interested!
could bring about major, unimagi-
nable, unstable and undeterminable E-hnail letters to to Tony@NFRcom.com. Or, send a Fax to: (952) 835-2295.
change in our heretofore successful

(TME FINANCIAL RUVII;W| 2.01.2009

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