In Europe, accounts were rooted in a governance system that emphasised stewardship and ownership, and depended on prudence and realisable values to ensure the protection of capital.
在欧洲,会计制度的基础是一套强调监督管理权和所有权的治理体系,并依赖于审慎原则和可变现价值来确保资本得到保护。
By contrast, in the US accounts evolved to facilitate trading in securities markets, which meant that more weight was given to neutrality and market valuations. It is not possible to have accounts that are both consistently prudent (emphasising judgment to avoid overstating capital or income) and neutral (emphasising current market valuations to eliminate “bias). The imposition of US-style “neutrality in Europe has removed the glue that binds together accounting and corporate governance.
相比之下,在美国,会计制度的发展旨在为证券市场的交易活动提供便利,这意味着要更侧重中立性和市场估值。一贯审慎且中立的会计报表是不可能存在的,审慎原则着重于判断,力求避免夸大资本或收入,中立原则侧重当前市场估值,力求消除“偏见。美国式的“中立原则在欧洲的强制推行,切断了将会计和公司治理联系在一起的纽带。
IFRS has been particularly pernicious in banking. In the run-up to the financial crisis, banks were prevented under IFRS from provisioning for expected loan losses. They were instead required to implement an “incurred loan loss provisioning model, which only permitted funds to be set aside for loans that were already going bad. Under IFRS, because riskier loans are associated with higher interest payments, banks are able to “cash in higher margins up front without allowing for the costs of expected defaults. In effect, banks’ accounts fail to present a “true and fair view of their economic health.
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