In mid-January 2003, the Financial Accounting Standards Board released its "final" draft of Financial Interpretation No. 46, which - though widely anticipated - tore through the industry like firestorm. And yet the interpretation, and the subsequent move by FASB to take the reigns of the QSPE project, have so far proven more symbolic than practical - symbolic, perhaps, of the inanity in efficient rulemaking while under political scrutiny. Devious accounting has been the backbone of too many corporate scandals in the last two years.
As the rules were published, the assets and liabilities in a typical multi-seller ABCP conduit - along with other non-QSPE securitization structures - would end up on the balance sheet of the sponsoring institution, an issue of great concern for U.S. GAAP compliant banks. At first glance, it appeared this consolidation would have an impact on risk-based capital ratios, as well as leverage ratios.