Abstract

Valuation and Layout Questions relating to Bank Balance Sheets as Proposed by an EC Directive on the Annual Accounts of Banks

The EC directive on the annual accounts of companies, which was issued in summer 1978, provides for separate co-ordination in this field in the case of banks and other financial institutions. In the course of this co-ordination, in autumn 1977 an international study group submitted a proposal and in summer 1980 the EC Commission presented a draft for a directive. The critical analysis of the article is oriented essentially to the proposal of the international group of experts. The points dealt with in detail as central problems of both documents are the envisaged valuation and layout rules; an attempt is made to base them on the empty English concept of a true and fair view. Here again the chief question is whether the existence, formation or dissolution of reserves in the case of banks must always be disclosed. In the critical ventilation of this issue it is emphasized that a true and fair view is not an ultimate objective of economic policy, but an intermediate goal that conflicts with other intermediate goals of economic policy, e.g. with those of competition policy, banking policy, etc. They include also the safeguarding of the functional efficiency of the commercial banking system in the special sense that fluctuating statements of earnings should not lead to doubts regarding the soundness of individual banks or a number of banks, which are basically functionally efficient and solvent. Only if it could be stated with certainty that exaggerated reactions of customers are not to be expected would it be possible perhaps to dispense with undisclosed reserves. But this question is completely open and caution is therefore advisable on the part of economic policy-makers. The envisaged, far-reaching publicity regulations should be judged in a similar manner. In comparison, the remaining points of the two documents analysed are of less significance, though by no means unimportant. The article presents a fairly complete critical survey.