The pragmatic and ethical distinction between two approaches to accounting policy making

REPLY TO COMMENT

The Pragmatic and Ethical Distinction Between Two Approaches to Accounting Policy Making Robert G. Ruland

Ruland (1984) utilized the centuries of debate in the ethics literature to analyze the philosophical underpinnings of the economic consequences issue in accounting policy making. Ingram and Raybum (1989) have questioned the premise of the economic consequences issue, i.e., that the representational faithfulness/user-needs approach to accounting policy making is distinct from the economic consequences approach. In this paper it is argued that the distinction is valid on both a pragmatic basis and an ethical basis. Many of Ingram and Raybum’s criticisms are grounded in misinterpretations of Ruland, and in reasoning which I find questionable. Most importantly though, their criticisms reflect a misunderstanding of the duty brought about by accounting’s role in society.

I appreciaie this opporhmity to clarify and expand on my previous work on ethics and accounting policy making. All too little research has been done on philosophical underpinnings of the accounting profession and its policy-making process. I hope that this response to the comments of Ingram and Raybum (1989) will make the ethical issues more clear. Ingram and Raybum (1989) contend that I view representational faithfulness and economic consequences as mutually exclusive approaches to establishing accounting policy when, in their view, these concepts are complementary. Although some of their points have been constructive, most of the criticisms raised by Ingram and Raybum (1989) are grounded in misinterpretations of my work, reasoning with which I do not agree, and a misunderstanding of the duty brought about by accounting’s role in society. Those who use the difficulty of Address reprintrequeststo: Professor Robert G. Ruland, Accounting tion, Northeastern University, 404 Hayden Hall, Boston, MA 02115.

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setting accounting policy as justification for a politically expedient approach to accounting policy making are advocating behavior which is both short-sighted and philosophically questionable. In the sections that follow, the mapmaking analogy and the relationship of truth to accounting are first discussed. Next, the discussion focuses on costbenefit analysis and how it can be expanded into consequentialism. This is followed first by a comparison of the role of consequences in the two approaches to accounting policy making, and second by a discussion of the provision of information for rational decision making as a nonconsequentialist approach. Acting and refraining, and relentlessness, as they relate to accounting policy making are then discussed in consecutive sections. Finally, there is a brief summary and concluding remarks.

Cartography,

Truth, and Accounting

Ruland (1984, p. 224) likens the faithful representations to satisfy user needs approach in accounting policy making to financial mapmaking. This analogy, which has been used by other authors as well (e.g., Solomons 1978, 1986), can be very illustrative of the issue facing accounting policy makers. It is worthwhile, therefore, to expand on prior discussions of the analogy. Ingram and Raybum (1989) criticize the use of the cartography analogy. However, when they claim that maps, like accounting reports, are “distortions of reality” whose representations necessarily result in a loss of accuracy, they are using the cartography analogy themselves. While this seeming contradiction is perplexing, the main point Ingram and Rayburn (1989) make about the analogy is that accounting reports are not maps because accounting classifications and aggregations are subjectively, not empirically, based. As an example, they (1989) claim that one’s location can be determined without reference to a map, while accounting amounts (e.g., profits, losses, and book values) have no meaning independent of the accounting process. The example is overly simplistic, however. When travelers are at a crossroads, they can often determine their location by looking at either a road map or at less formal sources such as signs and landmarks. The information of interest is location because information about location will aid decisions as to the direction in which to proceed. This is not to say that travelers would be indifferent to having a good road map, even in the presence of signs and landmarks which allow them to determine their location. A good road map provides more information about the context of the current location (what is nearby), alternative routes to the desired location, and the intermediate points that will be encountered, than do signs and landmarks. The same can be said about the relationship between accounting reports and information available from less formal sources. When individuals are trying to determine their income and wealth, they may refer to personal financial statements (assuming they are faithful representations of income and wealth) or

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they may refer to less formal sources like their lifestyle and their bank balance. Just as a map provides more information about location than do signs and landmarks, accounting reports provide more information about revenues, expenses, resources, and obligations than does observable financial information. This not to say that all maps are good maps and that all financial reports are good financial reports. A good road map faithfully represents the. attribute(s) of interest to users of the map and thus allows users to establish location and the desired direction. Good financial reports faithfully represent the attribute(s)’ of interest to financial statements users so that they may determine income and wealth and make financial decisions. Depending on the relevance to users of the attribute(s) being measured and the faithfulness of the measurements, the features on a map may or may not be good indicators of location or, in the case of accounting, profits, losses, and book values may or may not be good indicators of income and wealth. Ingram and Raybum (1989) imply in their example that income and wealth are not real concepts, but are defined by accounting measurements. Granted, income and wealth are more pragmatic and anthropological than metaphysical, but by definition they are real concepts to rational individuals. Accounting does not define income and wealth, it is an attempt to represent them through economic measurements. Given the behavioral nature of the concepts, it is not always clear how they are best represented.2 This is why debate over which accounting practices are best is continual. But, given a user orientation, good accounting is usually distinguishable from bad accounting. Thus, the debate should not concern how to define reality, but how to represent reality. More importantly, there is a difference between struggling to represent a hard to define, pluralistic reality and purposely misrepresenting it. The first case may be difficult and frustrating, but the second case is wrong because, as is argued in Ruland (1984) (and reviewed in the next section), it violates the obligation and duty of accounting policy makers. The cartography analogy helps illustrate the distinction between attempts at representation and deception. For example, some highway maps highlight scenic routes. This is clearly an attempt to satisfy the needs of users who are traveling for pleasure. But, some travelers prefer pastoral scenery, others rugged mountain views, others picturesque villages, and so on. A single highlight color will not satisfy all users, all the time. Mapmakers have a choice of whether to use different color for different types of scenery or to have one general purpose color. In either case, mapmakers would be making judgments and the result would be imperfect representations to at least some users. ’ If users differ in their definitions of income and wealth, they may desire measures of different attributes. Like a good atlas for diverse user needs, good financial reports may (if needed) provide multiple maps of a single entity. * It is clear, however, that accounting can influence perceptions of income and wealth. But it is a big jump to say that influencing perceptions of a concept defines the concept. Accounting measurements refine, but do not define, users’ perceptions of income and wealth.

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In spite of these complications, it .would be wrong in an ethical sense to discard users’ scenic preferences as too diverse and to instead misrepresent the scenic routes in order to effect some particular economic consequence. A cartographer could manipulate users by showing all routes to a certain city or tourist attraction as scenic. This might benefit some city’s economy and, perhaps, be supported by its chamber of commerce. But, it would violate the obligation and duty of map makers to provide faithful representations. Ingram and Raybum (1989) claim at one point that they know of few who have advocated a “pursue good, avoid bad consequences” approach to accounting policy choice. Later in their comment they say that they know “of no one who has advocated such a radical position.” This contradiction is perplexing, but what is more perplexing is their labeling the position radical when at points in the paper they seem to embrace the position.3 For instance, they criticize the illustration of a troubled debt restructuring with renegotiated terms. According to Ingram and Raybum (1989), that an expected cash stream which is altered results in a gain or loss is “an accounting interpretation which is meaningless apart from some general agreement as to how it is to be represented.” This implies that there are no economic truths to constrain the agreement as to the proper representation. But, that the value of a stream of cash flows is its present value is an accepted economic fact. Furthermore, there is general agreement on the validity of present value as a concept to be applied to cash flows in accounting reports. Reporting any other number is potentially deceptive to users. In short, maps and financial reports each provide representations which may require both technical and subjective measurements and interpretations by their preparers. Good financial reports, like good maps, provide more useful information than can be gathered from limited observation. Both maps and financial reports can be deceptive, rather than representative. Thus, the cartography analogy is illustrative of the issue facing accounting policy makers.

Costs, Benefits, and Consequences Ingram and Raybum (1989) further legitimize the “pursue good, avoid bad” definition of the consequences approach to policy making when, in their section on the role of economic consequences, they discuss the costs and benefits of accounting standards. Ingram and Raybum (1989) seem to view the incorporation of information on economic consequences as a natural expansion of the costbenefits concept. The cost-benefit concept is widely accepted as a materiality threshold for usefulness of an accounting standard. In general terms, the concept is that the information production costs associated with a standard should not exceed the value of the benefits received by users from the information the standard provides. 3 The issue has also been raised by other authors including

Swieringa

[1976] and Sprouse

[ 1987

& 19881.

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The problem with this concept is that it trades off the costs of one group, information providers, against the benefits of another group, information users. Given the problems which exist with other approaches to determine materiality, cost-benefit analysis at this level may be a necessary compromise in a representational faithfulness oriented accounting policy making system. But, expansion of the cost-benefit concept constitutes a fundamental departure from the faithful representations model. As a possible expansion, Ingram and Raybum (1989) inquire as to whether tax consequences, management decision impacts, and the effects on contracts ought to be considered as costs of accounting policies. But, for ethical reasons, these costs ought not to be traded off against the benefits users will receive from more faithful and/or more decision-useful reporting. The reasons, as discussed in Ruland (1984), are threefold. First, the accounting profession has created a prima facie obligation (Ross 1930, p. 119) to serve users of accounting for the economic consequences reports. Second, the “positive responsibility” of faithful representations lies with parties other than accounting policy makers, while the policy makers hold only a weaker “negative responsibility” (Williams 1973, pp. 93-100). Third, the duty to refrain (Foot 1967, p. 13) from a departure from faithful representations is stronger than the duty to act to affect good or avoid bad consequences. The prima facie obligation arises from an implicit promise to tell the truth which emanates from the history of the public accounting profession and which is reinforced (and profited from) by the profession today. The positive responsibility for the tax consequences lies with the taxing authority (primarily the Congress). Dysfunctional management decisions are the positive responsibility of dysfunctional managers and the boards of directors to which they report. While, the effect on contracts is the positive responsibility of those who naively write contracts which reference accounting numbers, but not the rules (by effective date or otherwise) by which the numbers are to be determined. The duty to refrain exists because acts of policy making which call for departure from faithful representations are the policy makers’ own unethical acts. In summary, Ingram and Raybum (1989) imply that economic consequences are the appropriate costs to be considered by policy makers. To make this implication while labeling the “pursue good, avoid bad” definition of the economic consequences approach “radical” is perplexing, at best. The economic consequences issue in accounting policy making is real. Rather than debate its existence, more time should be spent discussing the ethical issues involved in the accounting debate.

Role of Research Ingram and Raybum (1989) contend that the economic consequences approach to accounting policy making is primarily a positive rather than a normative approach. Furthermore, they claim that Ruland (1984) misrepresents those who

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advocate a role for consequences in policy making as calling for the pursuit of good and the avoidance of bad economic consequences. Unfortunately, Ingram and Raybum have overly simplified and, thus, misinterpreted my position on the role of consequences in accounting policy making. The role of research into economic consequences in the faithful representations approach to policy making was not discussed in Ruland (1984). It is, however, discussed in Ruland (1982). Briefly, it is inarguable that, as Ingram and Rayburn (1989) claim, economic consequences research is important to understand the effects of accounting policies on lobbying activities, management’s accounting choices, and users’ investment decisions. It is of no surprise that Ingram and Rayburn (1989) can cite research into the consequences of accounting standards that does not advocate the setting of standards to effect certain results. Economic consequences give important feedback on the accounting policy-making process and on the usefulness of accounting standards. The most important of these consequences to representationally faithful accounting policy making is the effect on investment decisions, since this provides feedback on the value of the information to users. I have participated in research of this general type myself (see Bernard and Ruland 1987, forthcoming). If accounting information results in irrational or otherwise unsuccessful investing, it may indicate the need for better education of users, or a reevaluation of the representational faithfulness and perhaps the relevance of the information to users. These implications of economic consequences research are radically different from the implications under the consequentialist approach to accounting policy making. Under the consequentialist approach, accounting standards would be devised to, and if necessary, subsequently revised to bring about certain social welfare effects. Users might or might not have primacy when determining what consequences are desired, and there would be no overriding obligation and duty to faithful representations. Information on the economic consequences of accounting standards would not just provide feedback on the policy-making process and on the usefulness of the standards under the consequentialist approach, it would provide information to guide the policy making process. Thus, the contention of Ingram and Rayburn (1989) that I misrepresent those who have advocated a role for economic consequences in accounting policy making is wrong. Obviously, economic consequences research is positive (and perhaps even explanatory) in nature. The question is, what are the normative implications of the research?

Rational Decision

Making

Ingram and Rayburn (1989) quote Ruland (1984) as defining consequentialists as those who recognize that alternative accounting standards have differing social welfare effects. Inexplicably, the quote is taken out of context and the

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definition is miscast. The quote in its correct context appears on page 57 of their comment. In the complete passage, consequentialists are defined as those who recognize: . . . that alternative accounting standards will have differing social welfare effects. Thus, they argue, accounting standards should be chosen that have a positive, or at least nonnegative, impact on social welfare . ..” (Ruland 1984, p. 224). What is more important than their misquote, however, is their claim that an approach to accounting policy making which emphasizes information for rational decision making (decision-useful information) is itself a consequentialist view. Clearly, some sort of consequences justify all acts and/or rules.4 The rule “tell the truth” is justified because the consequence of abiding by or violating the rule is truth or deception. But, there is a difference between justifying rules with intermediate consequences and justifying them with ultimate consequences. It is the reliance on ultimate consequences which distinguishes consequentialist philosophies from deontological, nonconsequentialist approaches. The providing of information to support rational decision making gives rise to an intermediate consequence, provision of the opportunity to make rational decisions. Ultimate consequences like maximization of the gross national product, or a just distribution of goods in society, are not the objective under the nonconsequentialist approach. Even the further intermediate consequence, rational decisions, is not the objective, though the nature of the decisions made may be valuable feedback on the quality and quantity of the information provided. The objective, under the nonconsequentialist approach, is to fulfill the obligation and duty to users of accounting reports by providing information for rational decision making. If Ingram and Rayburn (1989) are suggesting with their criticism that providing faithful representations which are decision-useful will have the best consequences, I agree (see Ruland 1988). However, this approach to accounting policy making is not right because it is good (i.e., because it has the best consequences). It is the right approach because it is ethically right, regardless of the consequences.5 That the ethically right approach has the best social welfare effects is an unsurprising yet pleasing condition. But it is neither necessary nor sufficient to ethical behavior in the accounting policy making context. Moreover, any analysis of the consequences of various approaches to

4 Gas and Smith (1985, p. 228) cite Scanlon (1978) as support and question whether a right can be justified without regard to its consequences. In fact, this is a complex issue which is the subject of ongoing debate in the ethics literature. What is impatant is that a right can be justified without reference to ultimate consequences. 5 As important as the consequentialist-nonconsequentialist distinction is the strictness of rights in the face of severe consequences. ScanIon (1978), while a supporter or rights, feels that rules based on rights are not inflexible. As an example, he states that a rule limiting each family to one bucket of well water per day during a drought should be violated in the case of a wellhouse tire. [ 1978, p. 1031 But, in the accounting policy-making context, there is no equivalent to a pumphouse fire. Other mechanisms are available to cause the desired good or stave off the undesirable bad consequences. Furthermore, those who control these alternative mechanisms have a stronger responsibility for the consequence than do accounting policy makers.

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accounting policy making will surely be criticized by some for the criteria used in judgment. This is because inherent in a consequentialist approach, is the consequences to whom and of what sort issue. Demski (1973, p. 720) has demonstrated distributive problems in choosing normative accounting standards. Gaa (1986) establishes the logical foundation for users as the target group for consequences maximization, but many assumptions are required and he does not advocate a position in this controversial area. In short, the faithful representations/decision-usefulness approach to accounting policy making can be justified on more than its ultimate consequences. Accounting policies do have consequences, and in a profession debating consequentialism as an approach to policy making, it is useful to know what the consequences are of the alternative policy-making approaches. But, no matter what the outcome of the analysis of consequences, the fundamental difference between what is right and what is good remains.

Acting and Refraining Duty is an ethical concept, where a duty may be to refrain from unethical behavior or a duty may be to act in an ethical manner.6 Ruland (1984) argues that the distinction is valid in the accounting policy-making context, and that the duty to refrain from presenting representations which are less than faithful is stronger than the duty to act in pursuit of good economic consequences. Ingram and Raybum (1989) take issue with this interpretation of the acting and refraining dichotomy in the accounting policy-making context. According to their view, the pursuit of faithful representations requires acts of policy making which sometimes violate the duty of accounting policy makers to refrain from causing negative social welfare effects. However, central to the proper interpretation of the conflicting duty dichotomy in the accounting policy-making context are the ethical concepts of obligation and responsibility. Recall that accounting policy makers have a prima facie obligation (or duty) to provide faithful representations to satisfy user needs. This obligation is in contrast to a negative responsibility to produce good (or avoid bad) consequences through their policies. The obligation supersedes the responsibility and, thus, accounting policy makers have a duty to issue standards which produce faithful representations to satisfy user needs. Issuing standards to produce the best consequences is unethical if the standards violate the duty to faithful representations. In other words, policy makers must refrain from issuing standards which violate their duty to decision useful faithful representations. This is not to say that accounting policy makers are unable to act in such a

6 The distinction between duties to act and duties to refrain has been discussed by many philosophers including Foot (1967), E&met (1966), Rachels (1975). and Abelson (1982). Terms like positive and negative duties, to do or to let happen, and acts and omissions are often used to describe what is here referred to as the act/refrain distinction.

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way that better consequences result. Given that faithful representations which are decision useful can be expected to have good consequences, it is clear that accounting policy makers can act to produce better consequences by improving the quality and quantity of decision useful information up to some optimal point. This is consistent with classical economic models that call for perfect information. It is also clear that, in at least some circumstances, the failure to issue standards which require decision-useful, faithful representations is an act of omission which actually violates the duty to refrain from less than faithful representations. The area of off-balance sheet financing provides a good illustration of this point. If some liabilities are not included on the balance sheet, the line termed total liabilities is clearly a misrepresentation which, if sanctioned by accounting standards, is in violation of the duty of accounting policy makers to refrain. While less clear, it probably would still be a violation if the line were termed since decision-useful information is being “total of the above liabilities,” withheld and this violates the duty of accounting policy makers. But, even if after a careful analysis it was determined that truth in labeling made the omission of information ethically neutral, it would be because the duty to refrain from less than faithful representations was not violated.

Faithful Representations and Relentlessness Ingram and Raybum (1989), in conjunction with their recasting of the actingrefraining dichotomy in the accounting policy-making context, claim that the pursuit of faithful representations is relentless. They claim that representational faithfulness is impossible to achieve, and that fewer FASB standards would exist if economic consequences as well as representational faithfulness were pursued. It is pleasing to see Ingram and Raybum (1989) at least partially embrace the need for faithful representations. However, this position seems inconsistent with others they have expressed in their comment, especially the one implied by the troubled debt-restructuring example. Regardless, the pursuit of decision useful faithful representations is not relentless, because it is measurement oriented, and because decision usefulness limits the attributes that need to be measured, while materiality guidelines limit the precision required of the measurements. This is in contrast to the pursuit of good economic consequences since, in a world of scarcity, changing economic conditions, and changing political conditions, there are always more or different “good” economic consequences to pursue. In other words, decision useful faithful representations is a more clear objective in a complex world than is good economic consequences. As for the speculation of Ingram and Raybum (1989) that there would be far fewer accounting standards if economic consequences were considered, it seems unfounded. There are at least two sources of the proliferation of accounting standards that are not related to the pursuit of faithful representations. First, existing standards lack simplicity and theoretical consistency as a result of too

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much, not too little, political influence on the accounting standard setting process. Second, there is a need for greater professionalism (and, perhaps, professional ethics) on the part of practicing accountants.’ For example Statement of Financial Accounting Standards No. 13 (FASB 1976) could have stated that all noncancelable leases must be capitalized. Instead, a much more complex set of capitalization criteria were written in the interest of compromise. Practicing accountants proceeded to find loopholes so that their companies or their clients could avoid capitalization. Evidently, little thought was given to the users for whom accounting reports ultimately are prepared. The result has been a series of additional pronouncements and interpretations to close some of the loopholes. There would be far fewer standards if politics and a client, as opposed to a user, orientation had not been present. Troubled debt restructuring is an example where no pronouncement would be necessary if theoretical consistency between standards existed, and practicing accountants acted ethically. If all long-term cash flow streams were recorded at their present value, truly professional accountants would not need a standard on troubled debt, because the correct accounting treatment would be obvious. Instead, a compromise was fashioned in the interest of politics. The compromise is renown for both its complexity and its lack of representational faithfulness.

Summary and Conclusions Ingram and Raybum (1989) criticize Ruland (1984) for treating representational faithfulness and economic consequences as mutually exclusive approaches to accounting policy making. Their criticisms are primarily based on an oversimplification of the faithful representations approach, a miscasting of my view on the role of economic consequences research in accounting policy making, and a misunderstanding of the duty that obligates accounting policy makers. Ethics concerns how people ought to behave. Ingram and Raybum (1989) do not consider the voluminous ethics literature when discussing the proper approach to accounting policy making. Instead, their viewpoint better reflects the state that exists in our overly politicized accounting policy-making process than it prescribes for the process. Debate in the field or ethics is ongoing. Clearly, the analysis in Ruland (1984) is not beyond reproach. It is hoped that, this response will correct some of the misconceptions held by Ingram and Rayburn (1989) about the alternative approaches to accounting policy making, and allow for more discussion of the ethical issues involved.

’ Several authors have discussed the changed nature of professionalism proliferation of accounting rules (e.g., Gerboth 1987; and Zeff 1987).

in accounting and its relationship to the

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Policy Making

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