This seems like a new sense of the phrase, which has appeared intermittently in the more bearish end of the financial reporting and opinion spectrum. It used to be a synonym of "mark to make-believe", which was one of the popular "methods" during the events leading up to the 2008 bust:

http://www.economonitor.com/blog/2009/09/mark-to-make-believ...

The new usage does seem quite an apt term to describe what's being discussed here (whether it's correct or not is obviously up for discussion.)