Tentative Board Decisions
Tentative Board decisions are provided for those interested in following
the Board´s deliberations. All of the reported decisions are tentative and may
be changed at future Board meetings.
March 26, 2014 FASB Board Meeting
Going
Concern. The Board continued its redeliberations of its June 2013 proposed
Accounting Standards Update, Presentation of Financial Statements (Topic
205): Disclosure of Uncertainties about an Entity´s Going Concern
Presumption (Exposure Draft).
The Exposure Draft proposed that
entities would begin disclosures of going concern uncertainties when certain
early-warning disclosure criteria were met. In addition to early-warning
disclosures, SEC filers would assess whether there is substantial doubt about
the entity´s ability to continue as a going concern for a period of 24 months
after the balance sheet date.
In light of the feedback received on the
Exposure Draft, the Board decided not to require the proposed early-warning
disclosures. Instead, the Board decided to pursue an approach that would require
disclosures when there is substantial doubt similar to disclosures provided
today under existing auditing standards.
Definition of Going Concern
Presumption
The Board decided not to define the term going
concern presumption, but rather to specify that the going concern basis of
accounting would be used until an entity´s liquidation is imminent, which is
consistent with the provisions of Subtopic 205-30 on the liquidation basis of
accounting.
Substantial Doubt Definition, Assessment Period, and
Frequency of Assessment
The Board decided that the definition of
substantial doubt would incorporate a likelihood component defined
using the term probable, as used in Topic 450 on contingencies. In
addition, the Board decided that the assessment period for substantial doubt
would be one year from the date the financial statements are issued (or, for
nonpublic entities, the date financial statements are available for issuance).
The Board affirmed the proposed Update´s requirement to assess substantial doubt
at each annual and interim reporting period.
Information to Be
Assessed Including Management´s Plans
The Board decided that
information about conditions and events would be assessed as of the financial
statement issuance date (or, for nonpublic entities, the date financial
statements are available for issuance). The Board also decided that management
should consider the mitigating effect of its plans to the extent it is probable
that:
- Those plans will alleviate the adverse conditions within the assessment
period.
- Those plans will be effectively implemented.
The Board asked that
the staff draft the relevant provisions of the standard with respect to
information to be assessed and management´s plans for the Board´s review before
its next meeting.
Disclosures in Periods When Substantial Doubts
Exist
The Board decided that when there is substantial doubt about
an entity´s ability to continue as a going concern, the notes to the financial
statements should disclose:
- A statement indicating that there is substantial doubt about the entity´s
ability to continue as a going concern
- The principal conditions and events giving rise to substantial doubt
- Management´s evaluation of the significance of those conditions and
events
- Any mitigating conditions and events including management´s
plans.
Disclosures When Substantial Doubt Is
Alleviated
The Board decided to require management to disclose in
the financial statements when substantial doubt about an entity´s ability to
continue as a going concern has been alleviated primarily by management´s plans.
Those disclosures would include the principal conditions and events that
initially raised the substantial doubt, and management´s plans that alleviated
the substantial doubt, unless the information is disclosed elsewhere in the
financial statements.
Nonpublic Entities
The Board
decided that the disclosures would apply to both public entities and nonpublic
entities.
Next Steps
The Board directed the staff to
perform outreach on its tentative decision to make the assessment period one
year from the financial statement issuance date as compared with the alternative
of one year from the balance sheet date. The Board also directed the staff to
discuss the assessment period decision with the Private Company Council and the
Small Business Advisory Committee to better understand the implication of that
decision on nonpublic entities. The Board expects to continue redeliberations in
May 2014.
FASB
Ratification of an EITF Consensus and a Tentative Conclusion. The Board
ratified the following consensus reached at the March 13, 2014 EITF meeting and
approved issuance of the resultant Accounting Standards
Update.
Issue 13-D, "Accounting for Share-Based Payments When the
Terms of an Award Provide That a Performance Target Could Be Achieved after the
Requisite Service Period"
The amendments in the Update resulting
from this Issue apply to all reporting entities that grant their employees
share-based payments in which the terms of the award provide that a performance
target that affects vesting could be achieved after the requisite service
period.
A performance target that affects vesting and that could be
achieved after the requisite service period should be treated as a performance
condition. A reporting entity should apply existing guidance in Topic 718 on
stock compensation as it relates to awards with performance conditions that
affect vesting to account for such awards. That is, compensation cost
attributable to the period in which requisite service has been rendered should
be recognized when it is probable that the performance condition will be
achieved. The total amount of compensation cost recognized during and after the
requisite service period should reflect the number of awards that are expected
to vest and should be adjusted to reflect those awards that ultimately
vest.
No incremental disclosures will be required to those already
required by Topic 718.
For all entities (both public business entities
and all other entities), the amendments will be effective for annual periods and
interim periods within those annual periods beginning after December 15, 2015.
Earlier adoption will be permitted. Entities may apply the amendments either (a)
prospectively to all awards granted or modified after the effective date or (b)
retrospectively to all awards with performance targets that are outstanding as
of the beginning of the earliest annual period presented in the financial
statements, and to all new or modified awards thereafter. If the amendments are
applied retrospectively, the cumulative effect as of the beginning of the
earliest annual period presented in the financial statements should be
recognized as an adjustment to the opening retained earnings balance in that
period. Additionally, if the amendments are applied retrospectively, entities
may use hindsight in measuring and recognizing compensation
cost.
FASB Ratification of an EITF
Consensus-for-Exposure
The Board also ratified the following
consensus-for-exposure reached at the March 13, 2014 EITF meeting and decided to
expose the resultant proposed Update for public comment for a period of 90
days.
Issue 12-F, "Recognition of New Accounting Basis (Pushdown)
in Certain Circumstances"
The amendments in the proposed Update
resulting from this Issue would apply to an entity that is a business or
nonprofit activity, both public and nonpublic, when an acquirer obtains control
of the entity. While the recognition and measurement provisions of the proposed
amendments are elective, to comply with the disclosure provisions, all entities
would be required to assess at each reporting date whether an acquirer has
obtained control of the entity.
An entity whose control has been obtained
by an acquirer would be provided with an option to apply pushdown accounting in
its separate financial statements. The option to apply pushdown accounting would
be evaluated and can be elected by the acquired entity for each individual
acquisition separately. If the acquired entity elects the option to apply
pushdown accounting, it would follow the initial recognition and measurement
guidance in Topic 805 on business combinations to recognize and measure its
assets, including goodwill, liabilities, and equity. However, if the application
of Topic 805 results in a bargain purchase gain, the acquired entity would not
recognize that gain in its income statement.
The acquisition-related debt
incurred by the acquirer would not be recognized in the acquired entity´s
separate financial statements unless the acquired entity is required to
recognize a liability for such debt in accordance with other applicable U.S.
GAAP. For subsequent measurement, the acquired entity would follow the guidance
in Topic 805 and other applicable U.S. GAAP to account for its assets, including
goodwill, liabilities, and equity instruments.
The acquired entity
applying pushdown accounting would be required to provide the disclosures
required in Topic 805 (except Subtopic 805-50), as applicable, as if the
acquired entity were the acquirer. If the acquired entity does not elect to
apply pushdown accounting, it would disclose (1) that the entity has undergone a
change in control event whereby an acquirer has obtained its control during the
reporting period and (2) its decision to continue to prepare its financial
statements using its historical basis that existed before the acquirer obtaining
control of the entity.
Pushdown accounting would be applied prospectively
to an event in which an acquirer obtains control of the entity for which the
acquisition date is on or after this Issue's effective date, which will be
determined after the Task Force considers stakeholder feedback on the proposed
Update.
Accounting
for Identifiable Intangible Assets in a Business Combination (PCC Issue
13-01A). In preparation for the April 29, 2014 Private Company Council (PCC)
meeting, the Board continued its discussion from the January 22, 2014 Board
meeting about accounting alternatives relating to PCC Issue No.
13-01A,"Accounting for Identifiable Intangible Assets in a Business
Combination," for public business entities, private companies, and
not-for-profit entities. The meeting was educational; no decisions were
made.
Accounting
for Goodwill for Public Business Entities and Not-for-Profits. The Board
continued its discussion of how a public business entity and not-for-profit
entity would account for goodwill after a business combination. The Board is
considering the following alternatives:
- Amortize goodwill over 10 years or less than 10 years if an entity
demonstrates that another useful life is more appropriate. An entity would
make an accounting policy election to test goodwill for impairment at the
entity level or at the reporting unit level. It would test goodwill for
impairment only when a triggering event occurs. An impairment loss would be
measured as the difference between the carrying value of the entity and its
fair value (if goodwill is tested for impairment at the entity level) or the
carrying value of the reporting unit and its fair value (if goodwill is tested
for impairment at the reporting unit level). This alternative is consistent
with the alternative available for private companies.
- Amortize goodwill with impairment tests over its useful life, not to
exceed a maximum number of years.
- The direct writeoff of goodwill at the acquisition date.
- A nonamortization approach that uses a simplified impairment
test.
The staff updated the Board on the outcome of additional research
and outreach conducted on the direct writeoff approach and the simplified
impairment test, undertaken after the February 12, 2014 Board meeting.
The Board made no decisions at this meeting. It deferred any further
discussion until after the IASB has completed and issued findings on its
post-implementation review of IFRS 3, Business Combinations (expected
later in 2014).