Voluntary Fair Value Disclosures by Bank Holding Companies : The Role of SEC Dear CFO Letters

The SEC’s Division of Corporate Finance sent “Dear CFO” letters to certain registrants in 2008 requesting voluntary disclosures to improve transparency of Level 3 fair value measures and valuation of financial instruments in inactive or illiquid markets. We expect these bank holding companies were among the companies that the Division of Corporate Finance targeted. We consider the discussion points from the Dear CFO letters to identify the disclosures to analyze in this study. We find that disclosures about valuation techniques and the use of broker quotes or prices from pricing services are associated with increased information asymmetry and disclosures about the use of market indices or illiquidity adjustments are associated with decreased information asymmetry. When interacted with Level 3 assets, disclosures about changes in valuation techniques intensify the positive relation between Level 3 assets and information asymmetry and disclosures about asset-backed securities mitigate the positive relation between Level 3 assets and information asymmetry. Our study provides insight about the types of disclosures that impacted information asymmetries during the financial crisis. However, this setting of uncertainty and use of a small sample size may limit the ability to generalize these inferences to other time periods or other financial firms