+0.20% ABSTRACT THE RELATIVE PREDICTIVE CAPACITY OF TWO BANK EARNINGS MEASURES: AN EMPIRICAL EVALUATION BY Hugh A. Hoyt A controversy exists between bankers and accountants over which of two earnings measures should be presented as the final reported earnings figure on a bank's income statement. Bankers favor a figure, described as Net Operating Earnings, that excludes any provision for loan losses or any security gains and losses. Accountants favor a figure, described as Net Income, that includes some provision for loan losses and all security gains and losses. An investigation into the nature and causes of the controversy revealed that although there would be no controversy if it were not for the existence of the two disputed items (i.e., the provision for loan losses and security gains and losses), it remains unresolved for reasons unrelated to the arguments presented by both sides in support of their treatment of the two items. The investigation disclosed that the primary reason that the controversy remains unresolved is the belief, held by both bankers and accountants, that investors have single-figure fixation. According to this belief investors focus almost entirely on the final reported earnings figure in evaluating the current and potential performance of a firm while other financial data included in the published financial statements are largely ignored. Granted the existence of the belief in single-figure fixation, it was found that a secondary reason for the controversy is a disagreement between the opposing sides as to which of the two earnings measures is the most relevant to users of publicly Hugh A. Hoyt reported bank earnings. Initial efforts to obtain empirical evidence that would aid in resolving the controversy were focused on attempts to perform a study to determine the validity of the belief in single-figure fixation. Such a study was not found to be feasible. Subsequent efforts were focused on performing a study to determine which of the two earnings measures was the more relevant. Such a study was found to be feasible once "the capacity to predict future earnings" was specified as a surrogate for relevance. While the general purpose of the ”predictive" study was to obtain empirical evidence that would aid in resolving the controversy, the specific purpose was to determine the relative capacity of the two earnings measures to predict future all-inclusive earnings. For, it was argued, if one earnings measure were found to have a predictive capacity superior to the other there would be new evidence to support the presentation of the measure with the superior predictive capacity as the final reported earnings figure on the grounds that it was more relevant. All-inclusive earnings was specified as the relevant forecast objective on the grounds that it provides the best measure of a bank's future overall performance. Net Operating Earnings and Net Income per share were computed for each year of the twelve-year period ending in 1968 for each of 26 large commercial banks on the basis of data contained in the published annual reports of these banks. These per-share figures served as the sole input(s) to six linear forecast models which were used to obtain estimates of all- inclusive earnings per share one year in the future. The forecast models employed prior years' earnings figures for periods ranging from one to five years. The difference between forecast earnings and actual all- Hugh A. Hoyt inclusive earnings served as the measure of forecast error. Aggregations' of the annual forecast errors associated with each earnings measure over forecast-error-periods ranging from one to seven years served as the basis for determining the relative predictive capacity of the two earnings measures. A An analysis of the results of this study disclosed that Net Operating Earnings (the bankers' earnings measure) showed a superior predictive capacity for forecast-error-periods of two years or less in length whereas Net Income (the accountants' earnings measure) showed a superior predictive capacity for forecast-error-periods of four years or more in length with neither measure showing a superiority for the three- year forecast-error-period. Since both earnings measures were found to have superior predictive capacities over one or more forecast-error- periods considered to be relevant to users of a final reported earnings figure, neither measure could be unequivocably designated as being more relevant than the other. Consequently it was concluded that no new evidence was found to support the presentation of either Net Operating Earnings or Net Income as the final reported earnings ligure on a bank's income statement. THE RELATIVE PREDICTIVE CAPACITY OF TWO BANK EARNINGS MEASURES: AN EMPIRICAL EVALUATION By J“ ‘1 Hugh A: Hoyt A THESIS Submitted to Michigan State University in partial fulfillment of the requirements for the degree of DOCTOR OF PHILOSOPHY Department of Accounting and Financial Administration 1970 Copyright by Hugh A. Hoyt 1970 ~——-\ '\ ,l ACKNOWLEDGMENTS Many people were responsible in one way or another for my successfully completing the Ph.D. program. The following represents a weak attempt to thank those to whom I will be forever indebted. First, appreciation is expressed to the members of my dissertation committee, namely Professors James Don Edwards (chairman), Alvin Arens, and Leo Erickson for the time and effort spent in reviewing and construc- tively criticizing my thesis. It is a far better product for their efforts. Special thanks is also due Professor Edwards as chairman of the department for seeing to it that financial aid was available throughout my graduate career. I am also indebted to several faculty members and fellow doctoral candidates for providing needed encouragement and helpful suggestions during the formative and conclusive stages of this research effort. Those deserving special credit include Robert May, James Parker, Michael Crooch, Gerald St. Amand, and Elba Baskin, William Morris, Michael Lawrence and Professor Geraldine Dominiak. Without financial support completion of the Ph.D. program would not have been feasible. Therefore, my appreciation is expressed to Ernst & Ernst, the Earhart Foundation, the American Accounting Association, and the Michigan Accountancy Foundation for financing my graduate career. There is one other group of individuals who, while they did not play a direct role in helping me complete the Ph.D. program, were instrumental in providing me with the internal and external resources ii without which I would have been unable to begin, let alone complete, an undertaking of this nature. Specifically included in this group are Margaret Miller, Mary and Frank McHenney, Catherine and Harry Miller, Albert Neukom, Professors Russell Ogden and Oscar Collins, and, of course, my parents and brothers and sisters. Finally, I express my gratitude to my wife, Joan, who, in addition to doing all of the typing on my dissertation, provided constant support throughout the ups and downs of the Ph.D. program and to my sons, Mark and David. They were the sine qua non of my efforts. iii TABLE OF CONTENTS Page ACKNOWLEDGMENTS. . . . . . . . . . . . . . . . . . . .'. . . . . ii LIST OF TABLES . . . . . . . . . . . . . . . . . . . . . . . . . vi LIST OF FIGURES. . . . . . . . . . . . . . . . . . . . . . . . . viii Chapter I. INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . l 1.1 Purpose of Research . . 1 1.2 The Controversy . . . . . . . . . . . 1 1.3 Importance of the Controversy . . . . . . . . . 8 1.4 Current Status of the Controversy . . . . . . . 12 1.5 Scope and Methodology . . . . . . . . . . . . . 15 II. THE ITEMS INVOLVED IN THE CONTROVERSY. . . . . . . . . . 17 2.1 Introduction. . . . . . . . . . . . . . . . . 17 2. 2 Security Gains and Losses . . . . . . . . . . . 17 2.2.1 The Bankers' Position . . . . . . . . . 18 2.2 2 The Accountants' Position . . . . . . . 20 2.2.3 Proposed Alternative Accounting Treatment. . . . . . . . . . . . . . 22 2.3 The Provision for Loan Losses . . . . . . . . . 24 2.3.1 The Bankers' Position . . . . . . . . . 25 2.3.2 The Accountants' Position . . . . . . . 31 2.4 Summary and Conclusion. . . . . . . . . . . . . 33 III. FORMULATION OF AN EMPIRICAL STUDY DESIGNED TO AID 1N RESOLVING THE CONTROVERSY . . . . . . . . . . . . . . 34 3.1 Introduction. . . . . . . . . . . . 34 3.2 The Basic Reasons for the Controversy . . . . . 34 3.2.1 The Primary Reason. . . . . . . . . . . 34 3.2.2 The Secondary Reason. . . . . . . . . . 40 3.2.3 Summary . . . . . . . . . . . 42 3.3 Proposed Means of Resolving the Controversy . . 43 3.3.1 Test of Single-Figure Fixation. . . . . 43 3.3.2 Test of Relevancy . . . . . . . . . . . 45 3.4 Summary . . . . . . . . . . . . . . . . . . . . 48 iv IV. v. VI. APPENDIX A. B. METHODOLOGY . . . . . . . . . . . . . . . . . . . . . . 4.1 Introduction . . . . . . . . . . . . 4.2 Specification of the Forecast Objective. . . 4.3 Specification of Forecast Models . 4.4 Sample Selection and Data Source . . . . . . . . 4.5 Calculation of Earnings Per Share. . . . . . . . 4.5.1 Computation of Net Operating Earnings. 4.5.2 Computation of Net Income. . . . . . . . 4.5.3 Computation of a Normal Provision for Loan Losses . . . . . . . . . . . . . 4.5.4 Adjustment for Stock Dividends and Splits. . . . . . . . . . . . . . 4.6 Specification of a Forecast Error Measure. 4.7 Summary. . . . . . . . . . . . . . . . . . . . EMPIRICAL FINDINGS. . . . . . . . . . . . . . . . . . 5.1 Introduction . . . . . . . . . . . . 5.2 Identification of Evaluation Criteria. 5.3 Results Analyzed According to the Short- Run Criterion . . . . . . . . . . 5.3.1 Aggregation Procedures . 5.3.2 Observations . . . . . . 5.4 Results Analyzed According to the Long-Run Criterion . . . . . . . . . . . . . . . . 5.4.1 Aggregation Procedures . . . . . . . . 5.4.2 Observations . . . . . 5.5 A Plausible Explanation of One Trend in the Forecast Errors . . . . 5.6 Summary. . . . . . . . . . . . . . . . . . . . . SUMMARY AND CONCLUSIONS . . . . . . . . . . . . . . . Introduction . . . . . . . . . . . Review of Research Purpose and Design. . . Limitations. . . . . . . . . . Conclusions and Implications . . . . . . . . . . 6.4.1 Major Conclusion . . . . . . . . . . . . 6.4.2 Minor Conclusion . . . . . . . . . Suggestions for Future Research. . . . . Banks Included In The Study . . . . . . . . . . . . . Supplementary Tables To Chapter V . . . . . . . . . . . SELECTED BIBLIOGRAPHY . . . . . . Page 50 50 50 56 59 60 61 62 .63 68 68 69 70 7O 70 71 71 78 80 80 84 90 92 97 97 97 99 100 100 105 105 107 108 115 Table II. III. IV. VI. VII. VIII. IX. LIST OF TABLES Page Selected Data on Federal Reserve Member Banks, 1957-68 . . . . . . . . . . . . . . . . . . . . . . . 9 Selected Information About the Forecast Models. I O O O O O O O O O O O O O O O 0 O c O 0 O O 73 Mean Absolute Percentage Forecast Error: Forecast-Error-Period Equal to One Year . . . . . . . 75 Mean Deviation of Absolute Percentage Forecast Errors: Forecast-Error-Period Equal to One Year. . . . . . . . . . . . . . . . . . . . . . . 76 Number of Banks for Which Each Earnings Measure Produced the Lowest Absolute Forecast Error: Forecast-Error-Period Equal to One Year . . . . . . . 77 Number of Time Periods Contained in the Total Period Covered by Each Forecast Model for Each Multi-Year Forecast-Error-Period. . . . . . . . . . . 83 Earnings Measure with the Lowest Total-Period Mean Percentage Forecast Error and Lowest Total-Period Average Mean Deviation for Selected Forecast-Error-Periods . . . . . . . . . . . 93 Earnings Measure with Lowest Common-Period Mean Percentage Forecast Error and Lowest Common- Period Average Mean Deviation for Selected Forecast-Error-Periods. . . . . . . . . . . . . . . . 94 Earnings Measure with Lowest Total-Period Mean Percentage Forecast Error and Lowest Total- Period Average Mean Deviation for a Majority of Forecast-Error-Periods Covered by Each Forecast Model for Selected Forecast-Error- Periods . . . . . . . . . . . . . . . . . . . . . . . 95 Mean Absolute Percentage Forecast Error and Mean Deviation of Absolute Percentage Forecast Errors: Forecast-Error-Period Equal to Two Years . . . . . . . . . . . . . . . . . . . . . . . . 109 vi Page XI. Mean Absolute Percentage Forecast Error and Mean Deviation of Absolute Percentage Forecast Errors: Forecast-Error-Period Equal to Three Years . . . . . . . . . . . . . . . . . . . . . . . . 110 XII. Mean Absolute Percentage Forecast Error and Mean Deviation of Absolute Percentage Forecast Errors: Forecast-Error-Period Equal to Four Years . . . . . . . . . . . . . . . . . . . . . . . . 111 XIII. Mean Absolute Percentage Forecast Error and Mean Deviation of Absolute Percentage Forecast Errors: Forecast-Error-Period Equal to Five Years . . . . . . . . . . . . . . . . . . . . . . . . 112 XIV. Mean Absolute Percentage Forecast Error and Mean Deviation of Absolute Percentage Forecast Errors: Forecast-Error-Period Equal to Six Years . . . . . . . . . . . . . . . . . . . . . . . . 113 XV. Mean Absolute Percentage Forecast Error and Mean Deviation of Absolute Percentage Forecast Errors: Forecast-Error-Period Equal to Seven Years . . . . . . . . . . . . . . . . . . . . . . . . 114 vii Figure 10. LIST OF FIGURES Income Statement Format Advocated By Bankers. Income Statement Format Advocated by Accountants. Graphic Presentation of Two Earnings Patterns Graphic Illustration of Bias and Efficiency . Total-Period Mean Absolute Percentage Forecast Errors for Selected Forecast-Error-Periods: MOdel 81- o o o o o o o a o o o Total-Period Mean Absolute Percentage Forecast Errors for Selected Forecast-Error-Periods: Model 82. . . . . . . . . . . . . . . . . Total-Period Mean Absolute Percentage Forecast Errors for Selected Forecast-Error-Periods: MOdel S30 0 o o o o o o o o o o o o o o Total-Period Mean Absolute Percentage Forecast Errors for Selected Forecast-Error-Periods: Model R1. . . . . . . . . . . . . . Total-Period Mean Absolute Percentage Forecast Errors for Selected Forecast-Error-Periods: Model R2. . . . . . . . . . . . Total-Period Mean Absolute Percentage Forecast Errors for Selected Forecast-Error-Periods: MOdE]. R3 0 o o o o o o o o o o o o o o 0 viii qu5e 38 54 101 101 102 102 103 l()3 CHAPTER I INTRODUCTION 1.1 Purpose of Research The purpose of this research is to obtain empirical evidence that will aid in resolving the controversy that exists between bankers and accountants over the form and content of bank income statements. 1.2 The Controversy The controversy between bankers and accountants essentially involves a disagreement over which of two earnings measures should be presented as the final reported earnings figure on a bank's income state- ment. Bankers favor a figure, described as Net Operating Earnings, that excludes any provision for loan losses or any security gains and losses. Accountants favor a figure, described as Net Income, that includes some provision for loan losses and all security gains and losses. lankers contend that the presentation of Net Income as a final reported earnings figure would give a distorted indication of a bank's "earning power" since such a figure includes two items (i.e., a provision for loan losses and security gains and losses) that they consider to be of a nonoperating nature. Accountants argue that security gains and losses and loan losses are a normal part of a bank's operations. Therefore, they contend that a failure to include security gains and losses and some provision for loan losses in the determination of a final reported earnings figure is mis- leading. Edward T. Shipley, former chairman of the Accounting Principles Committee of the American Bankers Association and past president of The 1 Association for Bank Audit, Control, and Operations (NABAC) has summarized the controversy in the following manner: Among the subjects of continuing discussion in bank finan- cial reporting is the possible adoption of the so-called "all- inclusive" income Statement. This concept means simply that the income statement should reflect all income and expense items, including even extraordinary, nonrecurring items; the alternative approach reflects the idea that the income state- ment should reveal current operating performance and that extraordinary items, unrelated to operations for the period, should by-pass the income statement and be directly credited to or charged against the capital accounts. The SEC and the AICPA have tended to favor the all-inclusive income statement, although extraordinary items are expected to be presented "below the line," as additions to or deductions from net operating income in arriving at net income. In banking, the debate has centered on two important items, the creation of a bad debt reserve and the treatment of gains or losses on securities transactions. There are substantial reasons why the generally preferred all-inclusive income statement would be detrimental to the best interests of banks and investors in bank securities.1 Figures 1 and 2 illustrate the income statement format advocated by bankers and accountants, reSpectively.2 The underlined captions in the two examples represent the major areas of difference. Identical amounts are used in both of the examples for comparable revenue and expense items with the exception of the provision for loan losses. The major differences in the two illustrated income statements are described below. All references to amounts pertain to the figures listed in the "current year" column of Figures 1 and 2. The first difference in the two statements occurs in the treat- ment of a provision for loan losses. Figure 2 (the accountants' state- 1Edward T. Shipley, "Bank Accounting Principles: A Progress Report," Law and Contemporarerroblems, Vol. 32: No. 1 (Winter, 1967), p. 144. 2The format for Figure 1 was synthesized from an analysis of the 1968 annual reports of the fifty largest commercial banks. The format for Figure 2 was extracted, with minor modifications, from Audits of Banks: Supplement (Committee on Bank Accounting and Auditing of the American Institute of CPA'S, [New York: AICPA, Inc., 1969] , p. 5.). 3 STATEMENT OF INCOME For the Years Ended December 31, 19__ and 19__ Current Preceding Year Year Operating income: Interest on loans $1,000,000 $ 900,000 Interest and dividends on: U.S. Government securities 180,000 200,000 State and municipal securities 60,000 60,000 Other securities 10,000 8,000 Trust Department income 100,000 90,000 Service charges on deposit accounts 50,000 45,000 Other operating income 60,000 55,000 Total $1,460,000 $1,358,000 Operating expenses: Salaries $ 220,000 $ 200,000 Other employee benefits 15,000 15,000 Interest 480,000 460,000 Net occupancy expense of bank premises 55,000 52,000 Other operating expenses 56,000 65,000 Total $ 826,000 $ 792,000 Operating earnings before income taxes $ 634,000 $ 566,000 Less applicable income taxes 277,000 244,000 Net operating_earning§ $ 351,000 § 322,000 Net opeggting earnings per share $3.57 $3.22 Nonoperatingiadditions and (deductions): Securities gains (losses), less related income tax effect of $50,000 in 19__ and $100,000 in 19__ $ 150,000 $ (100,000) Provision for loan losses, less income tax reduction of $19,000 in 19___ and $21,000 in 19__ (19,000) (21,000) Other, less income tax reduction of $30,000 $28,000) --- Total § 103,000 $ (121,000) Transferred to undivided_profits $ 460,000 $, 201,000 FIGURE 1 INCOME STATEMENT FORMAT ADVOCATED BY BANKERS 4 STATEMENT OF INCOME For the Years Ended December 31, 19__ Operating income: Interest on loans Interest and dividends on: U.S. Government securities State and municipal securities Other securities Trust Department income Service charges on deposit accounts Other operating income Total Operating expenses: Salaries Other employee benefits Interest Net occupancy expense of bank premises Provision for loan losses Other operating expenses Total Income before income taxes and securities gainsg(losses) Less applicable income taxes Income before securities gains (losses) Securities gains (losses), less related income tax effect of $50,000 in 19__ and $100,000 in 19__. Income before extraordinary item (Loss) on sale of branch bank building, less related reduction in income tax of $30,000 Net income Earnings data per share: Income before extraordinary,item Exgggordinary item,,less related reduction in income tax Net Income Current Year $1,000,000 180,000 60,000 10,000 100,000 50,000 60,000 $1,460,000 $ 220,000 15,000 480,000 55,000 15,000 M § 841,000 $ 619,000 269,000 350,000 150 000 A 500,000 '(28,000) g 472,000 $5.00 (.28) $4.72 and 19__ Preceding Year $ 900,000 200,000 60,000 8,000 90,000 45,000 55,000 $1,358,000 $ 200,000 15,000 460,000 52,000 15,000 65,000 $ 807,000 $ 551,000 236,000 315,000 (100,000) 215,000 215 000 $2.15 $2.15 FIGURE 2 INCOME STATEMENT FORMAT ADVOCATED BY ACCOUNTANTS ment) includes a provision for loan losses of $15,000 in ”Operating expenses" whereas Figure 1 (the bankers' statement) contains no such item. The $15,000 figure represents what accountants would call a "normal" provision for loan losses in that it excludes that portion of the total tax-deductible provision considered to be of a contingency nature by them. Further discussion of the concepts of a "normal" provision and a contingency portion of the total tax-deductible provision is deferred until Chapter II. The inclusion of a normal provision for loan losses, adjusted for the related income-tax effect ($15,000 - $8,000 = $7,000), accounts for the only difference between the figure reported as "Net operating earnings" ($357,000) by bankers and the figure reported as "Income before securities gains (losses)" ($350,000) by accountants. Figure 1 does contain a provision for loan losses. However, the amount is shown as a nonoperating deduction from "Net operating earnings" and represents the total tax-deductible provision of $38,000 allowed the bank. Since the "Nonoperating additions and (deductions)" are shown net- of-tax, the amount of the provision for loan losses shown in Figure l is $19,000 ($38,000 - $19,000). The $12,000 difference between the provision for loan losses shown in Figure 1 ($19,000) and the net-of-tax provision deducted in Figure 2 ($7,000, as derived above) represents the contingency portion of the total tax-deductible provision. No such amount is contained anywhere in Figure 2 since the contingency portion of the total tax-deduct- ible provision for loan losses is considered by accountants to be a segregation of retained earnings. The $12,000 difference between the two provisions for loan losses accounts for the difference between the amount reported by bankers as "Transferred to undivided profits" ($460,000) and the amount reported by accountants as "Net income" ($472,000). The next noticeable differences in the two statements pertains to the location and identification of security gains or losses and extraordinary items. Figure 1 shows securities gains of $150,000 along with the provision for loan losses and an "other" deduction of $28,000 as "below the line" adjustments to "Net operating earnings". Figure 2 treats security gains or losses as an adjustment to "Income before securities gains (losses)" in arriving at ”Income before extraordinary itemV. 'In the absence of any extraordinary item, security gains or losses would represent the final adjustment in arriving at "Net income". Figure 2 describes in greater detail what Figure 1 shows as an "other" deduction and treats it as an extraordinary item in arriving at "Net income”. Incidentally, little attention has been focused on the treatment of extraordinary items in the controversy, presumably because such items do not loom large in relation to security gains and losses and the provision for loan losses. The final difference, of course, concerns the designation of a final reported earnings figure. Figure 1 shows "Net operating earnings" both as a gross and earnings-per-share figure to illustrate the bankers' preference for it as the final reported earnings figure even though it is not the final figure on the income statement. Figure 2 shows "Net income" as the final figure on the income statement in illustrating the accountants' preference for it as the final reported earnings figure. Although Figures 1 and 2 are merely examples, they do serve to illustrate that there can be a considerable difference between the final reported earnings figures advocated by both parties involved in the controversy. It is worth noting that although a controversy still exists over the appropriate form and content of bank income statements, significant advances have been made in the overall financial reporting practices of banks in the past ten years. Prior to the Securities Acts Amendments of 1964, not a great deal was done to provide bank shareholders and the investment community with needed information. Some larger banks had begun to publish income statements, but most bgnks limited their disclosure of their financial affairs to the dissemiggtion of the reports of condition [i.e., balance sheets] required by the various supervisory authorities. These reports, in forms prescribed by the Comptroller of the Currency, the Federal Reserve Board, the Federal Deposit Insurance Corporation (FDIC), or state supervisory agencies, were largely identical in format. They were filed quarterly with the agencies but were typically published, as required, twice a year. The similarity in the statements' appearance belied the lack of uniformity in the accounting principles employed in their preparation. Statements of one bank could not be safely compared with those of another, and the prescribed forms made no provision for footnotes to explicate the figures and the accounting techniques followed in arriving at them. Statements of fipgncigl,conditign did not revggl earnings eggept,§§_they might perhgps be deducible by cggparison of surplus gpd undivided pgofit figpres with the same acgpunts disclosed ingggrlier statements, comparative figures, showing changes from one statement to the next,,were neyer required and seldom provided. While most supervisory authorities did require the filing of annual reports of earnings and dividends, these were unavailable to the public. (Emphasis added.) 3 The Securities Acts Amendments of 1964 vested the regulatory authority for bank financial reporting with the respective federal agency responsible for supervising the bank generally. Thus, the Comptroller of the Currency became responsible for national banks, the Federal Reserve Board for state member banks, and the FDIC for insured state nonmember banks. Subsequently the Federal Reserve joined forces with the FDIC to produce substantially identical regulations in 1965.4 The Federal 3Shipley, p. 132. 4Code of Federal Regplations: Title 12 - ngks and Banking, sections 206.1-.71 (January 1, 1970 revision). Reserve's is the version most often referred to and is identified as Regulation F. The Comptroller of the Currency did not issue comparable regulations until 1967.5 Among other things, these regulations stipulated that banks begin providing their stockholders with annual financial statements which included an income statement and disclosed amounts relating to security gains and losses and the provision for loan losses. The income statement illustrated in Figure 1 is indicative of the effect that these new reporting requirements had on the published income state- ments of most large, publicly-held banks by the end of 1968. Thus, no longer is the argument between bankers and accountants so much over disclosure as it is over format and terminology. Both sides are willing to include the total amount of security gains and losses and some provision for loan losses in the income statement; they disagree as to the location of these items in the income statement and the designation of a final reported earnings figure. 1.3 Importance of the Controversy Two types of evidence are presented to indicate the importance of the controversy: (1) the size of the items involved in the controversy and (2) the publicity generated by the controversy. Table I contains data relating to Net Operating Earnings, security gains and losses, the provision for loan losses, and actual loan losses of Federal Reserve member banks for the twelve-year period from 1957-68. The data reveal that security gains and losses and/or the provision for loan losses have been material in relation to Net Operating Earnings individually or collectively for each of the twelve years. 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