Action Alert No. 04-20
May 20, 2004

NOTICE OF MEETINGS

OPEN BOARD MEETING
(Board meetings are available by audio webcast and telephone.)

Wednesday, May 26, 2004, 9:00 a.m.

  1. Financial instruments: liabilities and equity. The Board will discuss whether to focus on one approach—the reassessed expected outcomes (REO) approach—for determining classification, unit of account, measurement, and earnings per share (EPS) for financial instruments involving an issuer’s own shares. (Estimated 90-minute discussion.)

  2. Open discussion. If necessary, the Board will allow time to discuss minor issues with staff members on technical projects or administrative matters. Those discussions are held following regular Board meetings as topics come up.

OPEN EDUCATION SESSION

Wednesday, May 26, 2004, immediately following the Board meeting

The Board will hold an educational, non-decision-making session to discuss topics that are anticipated to be discussed at a future Board meeting. Those topics will be posted to the FASB calendar four days prior to the education session.

OPEN ROUNDTABLE DISCUSSION WITH RESPONDENTS TO THE FASB STAFF REQUEST FOR INFORMATION ABOUT ISOLATION OF TRANSFERRED ASSETS
(This meeting is available by audio webcast and telephone.)

Tuesday, May 25, 2004, 9:00 a.m. – 12:00 p.m.

The Board will hold a public roundtable discussion with several attorneys who responded to the April 9, 2004 FASB Staff Request for Information about isolation of transferred assets, in connection with the Board’s planned revisions to its June 10, 2003 FASB Exposure Draft, Qualifying Special-Purpose Entities and Isolation of Transferred Assets, which would amend FASB Statement No. 140, Accounting for Transfers and Servicing of Financial Assets and Extinguishments of Liabilities. The scope of the roundtable will focus on legal issues related to the isolation requirement of Statement 140, including the impact of setoff rights.

The Board will hold an additional public roundtable discussion related to isolation issues that apply specifically to regulated financial institutions on June 17, 2004. The Board expects to invite attorneys and regulators to that second roundtable.

BOARD ACTIONS

The Board Actions are provided for the information and convenience of constituents who want to follow the Board’s deliberations. All of the conclusions reported are tentative and may be changed at future Board meetings. Decisions are included in an Exposure Draft for formal comment only after a formal written ballot. Decisions in an Exposure Draft may be (and often are) changed in redeliberations based on information provided to the Board in comment letters, at public roundtable discussions, and through other communication channels. Decisions become final only after a formal written ballot to issue a final Statement or Interpretation.

May 12, 2004 Board Meeting

Interpretation of Statement 87. The Board discussed issues related to scope, effective date and transition, and implementation issues.

The Board decided to expand the scope of the project to amend FASB Statement No. 35, Accounting and Reporting by Defined Benefit Pension Plans, to apply the Board’s March 3, 2004 decision—that the obligation for cash balance pension plans with a market or market-related (variable) interest crediting rate should be measured by reference to the notional account balance, that is, to the measurement of accumulated plan benefits under Statement 35. The Board also asked the staff to research the implications of further expanding the scope of the project to amend the guidance on the selection of discount rates in Statement 35 to make that guidance consistent with the discount rate guidance in FASB Statement No. 87, Employers’ Accounting for Pensions. The Board deferred discussion of the transition and effective date of the amendment to Statement 35 until a decision is reached regarding the discount rate issue.

The Board decided the following with respect to the implementation issues considered:

  1. Service cost should be determined by the pay/principal credits allocated to employees’ notional account balances; similarly, interest cost should be determined by the interest credits allocated to employees’ notional account balances.

  2. The interest cost component of net periodic pension cost should be based on the actual interest credited to plan participants’ notional account balances for the period.

  3. For plans that contain a cash balance formula with a variable interest crediting rate, the assumed discount rate that should be disclosed is the discount rate used to measure the portion of the projected benefit obligation (PBO) that is not attributable to the variable cash balance formula. The PBO amount measured at that rate also should be disclosed.

  4. For mixed formula plans in which a cash balance pension plan formula has been integrated into traditional defined benefit pension plans (or vice versa) and an employee is entitled to the greater benefit of the two formulas, the PBO should be based on the formula that results in the greater of the two benefits to the participant at the plan’s measurement date.

The Board discussed the transition guidance for a particular fact pattern in which an entity has an unfunded accumulated benefit obligation (ABO) before the application of the Interpretation and upon application of the Interpretation, the unfunded ABO increases but the PBO decreases. In such instances, the Board decided that the following transition guidance should be applied:

  1. The increase in the unfunded ABO should be recognized in the income statement in a manner similar to the cumulative effect of a change in accounting principle.

  2. The decrease in the PBO would reduce unrecognized losses and prior service cost (the items giving rise to the unfunded ABO).

Financial instruments: derivatives implementation. The Board discussed staff revisions to Implementation Issue No. G25, "Hedging the Variable Interest Payments on a Group of Prime-Rate-Based Interest-Bearing Loans." The Board did not object to the staff’s recommended revisions to permit the use of the first-payments-received technique when the hedged variable interest payments for an interest-bearing financial asset are based on the same rate or index as the underlying for the hedging instrument or on (1) a financial institution’s prime interest rate, (2) the prime rate published in the Wall Street Journal, or (3) the interest rate for "bank prime loan" in Federal Reserve Statistical Release H-15, "Selected Interest Rates," provided that the underlying for the hedging instrument also is based on one of the above prime interest rates (even though it is not exactly the same prime interest rate on which the financial asset is based).

Also, the Board unanimously supported recommendations to reorganize the format of Implementation Issue G25 and allow outside review by the Derivatives Implementation Group and other selected constituents before that Implementation Issue is finalized.

The Board did not object to the staff’s posting of Implementation Issue G25, as revised consistent with Board recommendations, on the FASB website as cleared guidance after considering the comments received from the outside review.

Agenda decision: request to amend Statement 133. The Board discussed requests from constituents to add a project to amend FASB Statement No. 133, Accounting for Derivative Instruments and Hedging Activities, to permit the bifurcation of risks for both fair value and cash flow hedge accounting related to nonfinancial assets. The Board unanimously agreed not to add a project to the Board’s technical agenda at this time to amend Statement 133 to permit the bifurcation of risks for both fair value and cash flow hedge accounting related to nonfinancial assets. The Board also expressed a preference to consider this issue a high priority for discussion in a future coordinated project with the IASB.

FUTURE OPEN MEETINGS

The following is a list of open meetings tentatively scheduled through June. Because schedules may change, please check the FASB calendar before finalizing your plans. Revisions to this list since the last issue of Action Alert are highlighted in bold.

Wednesday, June 2, 2004—FASB Board Meeting
Wednesday, June 2, 2004—FASB Education Session
Thursday, June 3, 2004—Liaison Meeting with the American Accounting Association
Wednesday, June 9, 2004—FASB Board Meeting
Wednesday, June 9, 2004—FASB Education Session
Thursday, June 10, 2004—Liaison Meeting with the Financial Executives International
Friday, June 11, 2004—Liaison Meeting with the CFA Institute (formerly the Association for Investment Management and Research)
Wednesday, June 16, 2004—FASB Board Meeting
Thursday, June 17, 2004—Qualifying Special-Purpose Entities Roundtable Discussion
Monday, June 21, 2004—FASB Education Session
Tuesday, June 22, 2004—Financial Accounting Standards Advisory Council Meeting
Thursday, June 24, 2004—Equity-Based Compensation Roundtable Discussion, Palo Alto, CA
Tuesday, June 29, 2004—Equity-Based Compensation Roundtable Discussion, Norwalk, CT
Wednesday, June 30, 2004—FASB Board Meeting
Wednesday, June 30, 2004—Emerging Issues Task Force Meeting