“Auditors Didn’t Flag”

Silicon Valley Bank’s third-party auditors did not mention the underlying risk to SVB’s viability in its report, which the group issued two weeks before the bank’s collapse.

When KPMG LLP gave Silicon Valley Bank a clean bill of health just 14 days before the lender collapsed, the Big Four audit firm flagged potential losses on loans as a so-called critical audit matter. But the audit opinion was silent on what actually brought down the bank—its unrealized bond losses and ability to hold them given a reliance on potentially flighty deposits.
“The auditors failed to mention the fire in the basement or the box of dynamite on the first floor, but they did point out the peeling paint on the flower box,” said Erik Gordon, a University of Michigan business professor. “How could they miss the interest-rate risk?”

And this from Martin Baumann, ex-Chief Auditor at the Public Company Accounting Oversight Board and who had a leading role in designing the new measure:

Silicon Valley Bank’s unrealized losses in its bond portfolio appear to “meet every definition of a possible critical audit matter[.]”

A critical audit matter is a tool intended to help investors decode risks and uncertainties buried in financial statements, to make audit opinions actually useful.

Thus, how could the auditors have missed the larger risk? Why did they?

Or did they? Maybe this is a demonstration of the weakness of auditors being paid by the auditees for the audits.

One apparent weakness in the PCAOB’s existing requirements, though, is that banks can hide the risks in their portfolios by (re)characterizing some or all of their bond holdings as “hold to maturity” rather than as marketable and so required to report their (fluctuating) market value. But when the bonds are being held in even partial satisfaction of reserve requirements, maybe those “hold to maturity” bonds still should have their current market value reported to the public. After all, SVB had no intention of selling even its “marketable” long-term bonds. That is, until it began to experience deposit withdrawals at rates it could not fill without selling those long bonds immediately, and so at losses driven by the environment’s rising interest rates.

So—again I ask: why did SVB’s auditors not report that interest rate risk? KPMG may well have a valid reason for its silence on that risk, but it should say what that risk is.

In any event, it would be useful to see the timesheets of those auditors—when I worked as a defense contractor, my timesheets were required to be submitted with 10-minute intervals—so we in the public can know what those auditors were doing instead of their jobs.

Bound by the Prior Administration

In Tuesday’s Wall Street Journal‘s Letters section, Mr Serpico had some thoughts regarding Navy Public Affairs Officer Admiral (ret) John Kirby’s, occupying a seat at Biden’s table as National Security Council Coordinator for Strategic Communications, words on the Biden Afghanistan so-called withdrawal.

John Kirby, the National Security Council spokesman, said with a straight face that the Afghanistan withdrawal was executed with constraints previously set by the previous administration. In essence, it was former President Trump’s fault (“Joe Biden Isn’t Sorry About Afghanistan,” Review & Outlook, April 7).
You rarely see such an act of unashamed temerity. The Biden administration had seven months to make any changes it wanted to avoid the debacle that followed.
Are we supposed to believe that Mr Trump recommended giving up Bagram Air Base in the middle of the night? Did Mr Trump recommend that backward sequence for the removal of our Afghan partners, equipment, and personnel? Did Mr Trump recommend not telling our NATO partners that we were leaving?
Remember, it was President Biden who disregarded his internal military advice about leaving behind a residual force in Afghanistan. All of this hearkens to former Defense Secretary Robert Gates’s warning that Mr Biden “has been wrong on every major foreign policy and national security issue over the past four decades.”

What Mr Serpico said.

To which I make a minor correction: “You rarely see such an act of unashamed lying.”

And to which I add:

John Kirby…said with a straight face that the Afghanistan withdrawal was executed with constraints previously set by the previous administration.

What constraints, exactly? What Trump had set up was a series of milestones that as the Taliban met each one, the next step of our drawdown would follow, but if a milestone was missed by the Taliban, the deal was off. And that set of milestones had a residual force, large enough to be effective, remaining.

Further, that deal was no treaty; it was a President’s Executive Agreement. Executive Agreements routinely are withdrawn—entirely legitimately in process and usually for good cause, as well—by subsequent Presidents. Biden was not bound by Trump’s EA; Biden easily could have altered or rescinded it, just as he did with all of the other Trumpian EAs and Executive Orders he rescinded in the last 10 days of January 2021. He chose to ignore this one.

Biden wasn’t bound by anything other than his panic-ridden wish to get out of Afghanistan, no matter the cost, in lives, in national honor, in messaging to enemies like Russia and the People’s Republic of China.