The Need for a Cryptocurrency Accounting Standard: A Regulatory Analysis

This thesis seeks to examine a nascent topic pertinent to the future of investment reporting to participants in global capital markets: cryptocurrency reporting. In the age of investor freedom, low to zero brokerage fees, and digital ‘do-it-yourself’ investing, many investors and investing platforms have adopted the use of digital currencies. Since its inception in 2009, cryptocurrency has been surrounded by controversy, which impacted financial institutions holding it, companies using it in transactions, and investors trading it. With cryptocurrency’s inherent volatility and relatively little accounting guidance, these stakeholders have faced difficulty in making capital allocation decisions, properly recording their holdings and transactions, and learning how to engage in activities involving cryptocurrency. Moreover, cryptocurrency has caught the attention of market regulators due to these same factors. Our project directly addresses this topic and explores the accounting implications of using cryptocurrency based on currently available authoritative and non-authoritative guidance. We further examine the need for authoritative reporting guidance, the regulatory bodies responsible for prescribing reporting guidance, and potential recommendations for future accounting standards. We begin by defining cryptocurrency and distinguishing it from other digital assets in Section 2. In Section 3, we discuss the risks presented by digital currencies and their inherent volatility. In Section 4, we describe the ways in which businesses currently use, treat, and interact with cryptocurrency from both transactional and accounting perspectives. In Section 5, we review, consolidate, and present the current guidance on digital currencies from the Big 4 accounting firms. In Section 6, we investigate the cryptocurrency disclosures of five large public US companies through an analysis of their annual reports. In Section 7, we research the FASB and SEC and their standard-setting processes to determine which organization is best suited to provide guidance on cryptocurrency reporting. As part of this task, we consider the role of these two regulatory agencies, their views and attitudes toward cryptocurrencies, and their jurisdictions over this area of financial reporting. This examination involves regulatory and public policy research, to understand the standard-setting process within the applicable regulatory body. Finally, in Section 8, we directly engage in the standard-setting process by drafting a comment letter to the FASB which includes the results of our research, the necessity (or lack thereof) for authoritative reporting guidance, and key issues that the Board should consider.