(a) Prior to FAS 133 if companies qualified for hedge accounting their hedges were assumed to be perfect-no valuation or testing required. Currently under FAS 133 risk managers seeking hedge accounting treatment have to thoroughly document every hedge from the outset and explain why they are undertaking the transaction. They have to spot their derivatives to market every quarter no small feat for many instruments afterwards prove they are effectively hedging the underlying exposure.

It's this logic of having to pay for the sins of others that accounts for the deep resentment toward FAS 133. Several finance executives suspect the new rules have less to do with improving financial statements than with discouraging treasury departments from speculating with derivatives.

(b) Constructing synthetic swaps will engage replication of a swap by portfolios of bonds. These do not come under the considerations of FAS 133.