Counsel's opinion, page-23

Just my little 2c.
It's not out of the ordinary to seek legal opinion on an accounting position at all. There's truckloads of legal professionals making a living for interpreting accounting standards for accountants and providing advice to transfer the risk of interpretation from the accountant to the lawyer.

On operational cash-flows - I agree that this is probably the best metric to view PNC by. But the issue is if book purchases are cash outflows here, then a growing company will show negative operating cash. If book purchases are marked as investing cash outflows, then operating cash isn't reflective of the quality of the purchase/collection margin.

On Fair Value Method over Amortised Cost - All public companies in this space should be recording their books at FV. While FV leaves a bit more to interpretation valuation-wise, it promotes a balance sheet that's much more reflective of the underlying assets. Something closer to a 'true' balance sheet rather than a 'statutory' balance sheet. Having said that, using FV creates a black-box that increases risk of abuse and if the rest of the industry moves towards this method then I think we'll see some pretty horrific cases. I think that PNC management has the integrity to use it properly though.