The answer is redesign financial statements. Don't leave it to the FASB, which is like letting the foxes guard the henhouse.
The occasion for this reflection came today as Christine Varney announced a series of workshops aimed at improving the Merger Guidelines. Lots of interesting hints in this speech. I was particularly interested in this topic:
[W]e are interested in your views on the use of more direct evidence that is not strictly based on inferences drawn from increases in market concentration. There are several categories of such evidence worth exploring: (1) evidence of the actual, post-merger competitive effects of consummated mergers, (2) evidence of "natural experiments" obtained by looking across different geographic markets, time periods, customer categories, or similar product markets; (3) evidence of the firms' post-merger plans; (4) evidence of customer views of post-merger competition; (5) historical evidence of actual head-to-head competition between the merging firms; and (6) historical evidence of actual or attempted coordination in the industry. Although the Agencies routinely rely heavily on these kinds of evidence to assess competitive effects, the Guidelines address their relevance only in passing and only secondarily, after the relevant market is defined and concentration in that market is measured. Courts also regularly rely on this type of evidence in assessing competitive effects.28 We are interested in views on whether we should adjust the Guidelines to address explicitly what kinds of direct evidence are pertinent and how they should be weighed.
Is it too much to ask that the FTC and the SEC coordinate on this? Recall that Goldman Sachs CEO Lloyd Blankfein recently suggested reforming the accounting rules to require all exposure to flow through to financial statements. Not only might these kinds of reforms benefit the SEC in enforcing its rules, it would give the FTC a better source of data -- at least for public companies -- on which to base econometric analyses of substitutability, for example. Needless to say, investors and ultimately consumers would benefit from having better information too.
Long time readers of Broken Symmetry may recall earlier posts (here, here, and here, for example) on how financial statement report only snapshots in time and time-averages of sales and costs of sales. These were all that was needed when buying and selling patterns changed only annually, or at fastest quarterly. To handle more rapid changes, you have to increase the sampling rate. What we need is a time-series of balance sheet accounts, or income/cash-flow statements on shorter intervals.
Having better designed financial statements would benefit consumers far more overall than even perfectly clear merger guidelines or perfectly efficient SEC enforcement.
How hard would it be for economists from the FTC to sit down with economists from the SEC and hammer out a set of economic data that should be required from public companies but that isn't in the financial statements now? To make it palatable politically, they could offer to get rid of Sarbanes-Oxley hassles in exchange for more information. Have a time-delay of the release of real-time balance sheet info to deal with the trade secret issues.
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