Mark-to-market (MTM) is an accounting method that values assets and liabilities at their current market price rather than historical cost — recognizing unrealized gains and losses through income or other comprehensive income. Governed by FASB ASC 820 (Fair Value Measurement) and IFRS 13.
Mark-to-market accounting requires that certain financial instruments be carried at fair value on the balance sheet, with periodic changes flowing through the income statement (trading securities, derivatives) or other comprehensive income (available-for-sale securities). FASB ASC 820 (https://www.fasb.org/standards/accounting/asc/820) defines fair value as 'the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date' — a hypothetical exit price. ASC 820 organizes fair value inputs into three levels: Level 1 (quoted prices in active markets — most reliable), Level 2 (observable inputs other than quoted prices, such as matrix pricing or yield curves), and Level 3 (unobservable inputs requiring management judgment — least reliable, often used for illiquid assets like private loans and CLO equity). Banks and BDCs with large loan portfolios often have significant Level 2 and Level 3 assets requiring quarterly fair value estimation. For SBA lenders that elect fair-value accounting for servicing rights (MSRs), MTM creates income volatility: rising rates increase MSR value (gain recorded), falling rates decrease MSR value (loss recorded). For businesses with derivatives (interest rate swaps, caps), FASB ASC 815 requires MTM of those instruments with hedge accounting treatment available if specific criteria are met. For most SMBs, MTM is most relevant in understanding lender balance-sheet requirements — banks must MTM their trading books and derivatives, which affects their capital ratios and ultimately their lending capacity.
Banks must mark their trading books, derivatives, and some loan portfolios to market. When market values decline (credit spread widening, rising rates), bank capital ratios can deteriorate — prompting tighter lending standards and reduced credit availability. This is the 'procyclicality' critique of MTM: it can accelerate credit contraction in downturns. Understanding that your bank's lending behavior is partly driven by its own MTM accounting position is useful context for business borrowers navigating credit availability cycles.
Amortized cost accounting carries loans at their outstanding principal minus any allowances for credit losses (under CECL — ASC 326). No market price changes are recognized until an actual credit event occurs. MTM recognizes hypothetical exit prices continuously. For loans held to maturity by banks, amortized cost is the standard — but loan portfolios at BDCs and trading desks use MTM. The March 2023 bank failures (SVB) were partly driven by unrealized MTM losses on held-to-maturity bonds that weren't recognized until asset sales were forced.
ASC 820 is the FASB standard that defines fair value measurement for all entities applying US GAAP. It requires banks, BDCs, CLO managers, and any entity with financial instruments to establish and apply a consistent fair value hierarchy (Level 1-2-3). Auditors scrutinize Level 3 fair value estimates closely because they rely on management assumptions. For BDCs that mark their entire loan portfolio to fair value quarterly, ASC 820 is the primary framework governing NAV calculation.
No. Different accounting standards apply to different instruments. Trading securities (ASC 320): MTM through income. Available-for-sale securities (ASC 320): MTM through OCI. Loans held to maturity (ASC 326 CECL): amortized cost with allowance for expected credit losses. Derivatives (ASC 815): MTM through income unless hedge accounting applies. The classification determines the accounting treatment, and reclassification between categories is restricted.