The accounting rule-making process is an esoteric world, ensconced in a shell of specialist knowledge and removed from the eyes of the unschooled public. In this sense, it is largely immune from the dangers of populist policy making (although populism has from time to time been effectively wielded as a weapon in shaping rule-making outcomes, most notably in the case of determining accounting rules for employee stock options). But this technical world is not immune to political dynamics, as the preceding chapters have shown. Put differently, in the United States and beyond, across industrial companies, financial institutions, and audit firms, and over both substantive issues and the design of relevant institutions, the corporate accounting rulemaking process is at once deeply technical and political.
Those with the knowledge to shape accounting rules—corporate managers, defined to include auditors, bankers, and other financial intermediaries—accumulate such knowledge because of their experience and their concentrated economic interests in the outcome of the rule-making process. Conversely, those with dispersed interests—ordinary savers and the average citizen—rarely enjoy the expertise necessary to engage productively in rulemaking; acquiring such expertise is economically unviable given their limited interests. Accordingly, the political process of accounting rule-making is largely attended by a handful of keen special interests and largely ignored by the general interest. And, not surprisingly, the outcomes of this process, in several instances, skew toward the special interests and away from conceptual expectations of what accounting rules should look like.
In their efforts to shape accounting rules, the special interests have been aided from time to time by seemingly independent experts, including academics. For example, chapter 5 introduces evidence that academics who have served on the FASB since the mid-1980s have been unequivocally supportive of fair-value accounting. The overwhelming support for fair values among academics serving on the FASB is in contrast to the more contentious status of fair-value accounting in the wider academic community. The data suggest that academics on the FASB may have been selected for their predisposition to fair-value accounting—to provide conceptual validation to the special-interest groups advancing fair values. This explanation, if true, suggests that the regulatory model of the determination of GAAP is more nuanced than that derived from a straightforward application of capture theory. Rather, the regulatory model can be described as one of “ideological capture,” where prevailing special-interest groups co-opt certain conceptual arguments and associated experts to advance their agendas in the political process.
Furthermore, while a certain special interest might capture the political process in a given instance, there is little evidence of comprehensive capture. On a given issue, those with the strongest incentives and the deepest expertise have the loudest voice and an important say in the outcome. But the portfolio of accounting rules to be determined is broad—spanning all sectors of the economy—and the expertise necessary in each instance is considerable. Thus a special interest on one issue can be part of the general interest on another. Special-interest capture in accounting rule-making appears to be localized; the system itself is not beholden to any one group.
The behavioral model emerging from this description of corporate accounting rule-making is the pursuit of self-interest by participants during the political process. This is true of the corporations and investment banks lobbying on M&A and goodwill accounting in chapter 3, the Big N audit firms protecting themselves from liability in chapter 4, the investment banking and investment management professionals serving on the FASB seeking fair-value accounting rules in chapter 5; the Chinese state-controlled enterprises and the Indian multinational carving out self-serving protections in chapter 6, and the private-company interests pushing for their own regulator in chapter 7. Participants from across the spectrum seek to increase their own profits as they engage in the accounting rule-making game. This behavior is entirely consistent with the competitive spirit that underlies capitalism. Indeed, it embodies the moral imperative of competitive strategy, as Milton Friedman and many others have pointed out.
But capitalism encourages self-interest on the premise of competition; and competition—particularly competition from groups representing ordinary savers and citizens—is uncharacteristic of the accounting rule-making process. Thus the pursuit of profit, which otherwise engineers markets away from iniquitous amassment of wealth and power toward aggregate prosperity, produces a quilt of special-interest concessions in accounting rulemaking. This outcome is what I characterize as “political standards.”