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.
February 25, 2015 FASB
Board Meeting
Financial
Instruments—Hedging. The Board began redeliberations of the May 2010
proposed Accounting Standards Update, Accounting for Financial Instruments
and Revisions to the Accounting for Derivative Instruments and Hedging
Activities—Financial Instruments (Topic 825) and Derivatives and Hedging (Topic
815). The Board discussed the effectiveness threshold and qualitative
versus quantitative testing of hedge effectiveness, as well as component hedging
for nonfinancial items.
The purpose of this Board meeting was for the
Board to provide the staff with feedback on the alternatives presented. The
Board directed the staff to conduct additional research on the following
topics:
- Identifying additional hedging relationships that may qualify under a
reasonably effective threshold
- Developing a numerical threshold to define reasonably
effective
- Recognizing an impairment loss if, at any time, an entity believes that a
loss reported in other comprehensive income would result in recognizing a net
loss on the combination of the hedging instrument and the hedge
transaction
- Performing qualitative assessments of hedge effectiveness at each
reporting period after quantitative testing at hedge inception
- Allowing contractually specified components to be designated as the hedged
item
- Presentation of hedge ineffectiveness.
The Board made no technical
decisions.
Financial
Performance Reporting. The staff provided an update on its research into
different alternatives for describing and defining operating activities. The
Board discussed whether defining operating activities and whether displaying a
subtotal of the results from operating earnings would improve the relevance of
information presented in the performance statement. The Board directed the
staff to focus its research efforts on distinguishing between recurring and
nonrecurring or infrequent items for the next meeting, after which the Board
would consider how and whether it would like to proceed on defining operating
activities.
Leases.
The Board continued redeliberating the proposals in the May 2013 Exposure Draft,
Leases, specifically discussing the following topics: (1) reassessment
of variable lease payments, (2) lessee transition, (3) lessor transition, (4)
sale and leaseback transition, (5) build-to-suit lease arrangements, and (6)
sweep issue—lessee disclosure of the weighted-average discount rate for Type A
leases.
Reassessment of Variable Lease Payments
The Board
affirmed that a lessee should reassess variable lease payments that depend on an
index or a rate only when the lessee remeasures the lease liability for other
reasons (for example, because of a change in the lease term resulting from a
reassessment).
Lessee Transition
The Board decided to
require a lessee to apply a modified retrospective transition approach for
capital and operating leases existing at, or entered into after, the beginning
of the earliest comparative period presented in the financial statements (the
date of initial application). The modified retrospective approach would not
require any transition accounting for leases that expired before the date of
initial application. The Board decided to not permit a full retrospective
transition approach.
The modified retrospective transition approach
should be applied to existing leases as follows:
Capital
Leases
- A lessee should initially recognize a Type A right-of-use (ROU) asset and
lease liability at the later of (a) the date of initial application and (b)
the date of initial recognition under Topic 840, Leases, measured at the
carrying amount of the capital lease asset and capital lease obligation under
Topic 840 immediately before that date.
- Any unamortized initial direct costs not included in the capital lease
asset under Topic 840 that would have qualified for capitalization under the
new leases standard should be subsumed into the Type A ROU asset; otherwise,
those costs that would not have qualified for capitalization should be written
off as an adjustment to equity.
- Before the effective date, a lessee should subsequently measure the Type A
ROU asset and lease liability in accordance with the subsequent measurement
guidance in Topic 840.
- Beginning on the effective date, a lessee should subsequently measure the
Type A ROU asset and lease liability in accordance with the subsequent
measurement guidance in the new leases standard, except that a lessee should
not remeasure the Type A ROU asset or lease liability for changes in the
amount the lessee expects to pay under residual value guarantees unless it
remeasures the asset or liability for other reasons (for example, because of a
change in the lease term resulting from a reassessment).
- Beginning on the effective date, if a lessee modifies the lease (and that
modification is not a separate lease) or is required to remeasure the lease
liability for any reason, it should follow the new leases
standard.
Operating Leases
- A lessee should initially recognize a Type B ROU asset and lease liability
at the later of (a) the date of initial application and (b) lease
commencement.
- Unless the lease is modified (and that modification is not a separate
lease), or the lease liability is required to be remeasured, on or after the
effective date, a lessee should initially and subsequently measure the lease
liability at the present value of the sum of:
- The remaining minimum rental payments (as defined under Topic
840) plus
- Any amounts the lessee expects to pay to satisfy a residual value
guarantee, using a discount rate established in accordance with the new
leases standard as of the "later of" date.
- A lessee should measure the Type B ROU asset throughout the lease at an
amount equal to the lease liability, adjusted for any prepaid or accrued rent,
lease incentives, or unamortized initial direct costs that would have
qualified for capitalization under the new leases standard.
- Any unamortized initial direct costs at the "later of" date that would not
have qualified for capitalization under the new leases standard should be
written off as an adjustment to equity.
- Beginning on the effective date, if a lessee modifies the lease (and that
modification is not a separate lease) or is required to remeasure the lease
liability for any reason, it should follow the new leases standard.
The
Board further decided to permit a lessee to elect the following specified
reliefs, which must be elected as a package and must be applied to all of a
lessee´s leases (that is, they cannot be elected on a lease-by-lease or
relief-by-relief basis):
- A lessee need not reassess whether any expired or existing contracts are
or contain leases.
- A lessee need not reassess the lease classification for any expired or
existing leases.
- A lessee need not reassess initial direct costs for any existing leases
(that is, whether those costs would have qualified for capitalization under
the new leases standard).
Lastly, the Board also decided to permit a
lessee to elect to use hindsight with respect to lease renewals and purchase
options when accounting for existing leases. This specified relief may be
elected separately or in conjunction with the above specified reliefs as an
accounting policy election (that is, it cannot be elected on a lease-by-lease
basis).
Lessor Transition
The Board decided to require
a lessor to apply a modified retrospective transition approach for sales-type,
direct financing, and operating leases existing at, or entered into after, the
date of initial application. The modified retrospective approach would not
require any transition accounting for leases that expired before the date of
initial application. The Board decided to not permit a full retrospective
transition approach.
The modified retrospective transition approach
should be applied to existing leases as
follows:
Sales-Type/Direct Financing Leases
- A lessor should not reassess whether a sales-type lease would have
qualified for upfront selling profit recognition in accordance with the new
leases standard.
- A lessor should initially recognize a net investment in the lease at the
later of (a) the date of initial application and (b) lease commencement,
measured at the carrying amount of the net investment in the lease under Topic
840 immediately before that date. For a direct financing lease, the net
investment in the lease should include any unamortized initial direct costs
that were capitalized in accordance with Topic 840.
- Before the effective date, a lessor should subsequently measure its net
investment in the lease in accordance with the subsequent measurement guidance
in Topic 840.
- Beginning on the effective date, a lessor should subsequently measure the
net investment in the lease in accordance with the subsequent measurement
guidance in the new leases standard.
- Beginning on the effective date, if a lessor modifies the lease (and that
modification is not a separate lease), it should follow the new leases
standard.
Operating Leases
- The carrying amount of the underlying asset and any lease assets or
liabilities (for example, prepaid or deferred rent) should be the same as that
recognized under Topic 840 at the later of (a) the date of initial application
and (b) lease commencement.
- If a lessor had previously securitized receivables arising from leases
that were classified as operating leases in accordance with Topic 840, the
lessor should account for those transactions as secured borrowings in
accordance with other Topics.
- A lessor should recognize any initial direct costs that would have
qualified for capitalization under the new leases standard as an expense over
the lease term on the same basis as lease income; otherwise, those costs that
would not have qualified for capitalization should be written off as an
adjustment to equity as of the applicable "later of" date.
The Board
decided that a lessor may apply the same specified reliefs as permitted for a
lessee subject to the same restrictions. The Board decided that the specified
relief elections must be consistently applied by an entity for all lessee and
lessor leases (that is, an entity that is a lessee and a lessor must make the
same specified relief elections).
Lessee and Lessor Transition
Disclosures
The Board decided that lessees and lessors should
provide transition disclosures consistent with Topic 250, Accounting Changes and
Error Corrections, without the disclosure of the effect of the change on income
from continuing operations, net income, any other affected financial statement
line item, and any affected per-share amounts for the current period and any
prior periods retrospectively adjusted (that is, without the requirements in
paragraph 250-10-50-1(b)(2)).
Sale and Leaseback
Transition
Accounting for Previous Sale and Leaseback
Transactions
The Board decided that an entity should not
reassess whether a transaction previously accounted for as a sale and leaseback
transaction under Topic 840 would have qualified as a sale (or purchase) in
accordance with Topic 606, Revenue from Contracts with Customers.
The
Board decided that an entity should account for the leaseback in any transaction
that qualified as a sale and leaseback under Topic 840 in accordance with the
lessee and lessor transition requirements.
Deferred Gain or Loss
Treatment for Sale and Capital Leaseback
The Board decided that
for any transaction previously accounted for as a sale and capital
leaseback transaction under Topic 840, the seller-lessee should continue to
amortize any deferred gain or loss.
Deferred Gain or Loss
Treatment for Sale and Operating Leaseback
The Board decided
that for any transaction previously accounted for as a sale and operating
leaseback transaction under Topic 840:
- The seller-lessee should recognize any deferred gain or loss not resulting
from off-market terms as a cumulative-effect adjustment to equity at the later
of the date of initial application and the date of sale.
- Any seller-lessee deferred gains or losses that resulted from off-market
sales and leaseback terms should be recognized as an adjustment to the
leaseback ROU asset (if a deferred loss) or accounted for as a remaining
financial liability (if a deferred gain) at the date of initial
application.
Build-to-Suit Lease Arrangements
The Board
decided to affirm its current tentative decision to not include specific
guidance about lessee involvement in asset construction in the new leases
standard other than the guidance that was proposed in the 2013 Exposure Draft
(paragraph 842-40-55-2).
The Board decided to require a lessee to apply
a modified retrospective transition approach for build-to-suit lease
arrangements existing at, or entered into after, the date of initial
application. The modified retrospective approach would not require any
transition accounting for build-to-suit leases that expired before the date of
initial application.
The modified retrospective transition approach
should be applied to existing build-to-suit leases as follows:
- An entity that has recognized assets and liabilities solely as a result of
a transaction´s build-to-suit designation in accordance with Topic 840 should
derecognize those assets and liabilities at the later of (a) the date of
initial application and (b) the date that the lessee is determined to be the
accounting owner of the asset under existing build-to-suit guidance. Any
difference between the amounts of the assets and the liabilities derecognized
should be recorded as an adjustment to equity at that date. The lessee should
then follow the general lessee transition guidance for the lease itself as it
would have had the lease not been accounted for in accordance with the
build-to-suit guidance.
- For build-to-suit lease arrangements in which the construction period
ended before the date of initial application, but the lease term is not
expired as of that date, and the transaction qualified as a sale and leaseback
transaction under the existing guidance in Subtopic 840-40 before that date,
the entity should apply the lessee transition requirements.
Sweep
Issue—Lessee Disclosure of the Weighted-Average Discount Rate for Type A
Leases
The Board decided to require a lessee to disclose the
weighted-average discount rate for Type A leases as of the reporting date
together with the other quantitative disclosure requirements that were decided
by the Board at the January 2015 joint FASB/IASB Board meeting.
Next Steps
The Board will discuss private company
considerations at a future Board meeting. The staff will also begin drafting a
final leases standard based on the tentative decisions reached by the Board.
Later in the drafting process, the Board will discuss the benefits and costs of
the new leases standard, effective date, and any sweep issues that arise during
drafting of the final leases standard.
Financial
Statements of Not-for-Profit Entities. The Board discussed various issues
identified during the drafting of a proposed Accounting Standards Update. The
Board also discussed the proposed transition and effective date and comment
period length. Finally, the Board discussed a staff analysis of the expected
benefits and perceived costs of the proposed changes.
Alignment of
Operating Definitions in the Statements of Activities and Cash
Flows
The Board decided to maintain tentative definitions for
operations in the statements of activities and cash flows but decided to seek
input in the forthcoming Exposure Draft on whether and how those definitions
might be further aligned.
Presentation and Disclosure of Investment
Return
The Board decided not to require disclosure of unrelated
business income taxes or excise taxes that are netted against investment return
and to eliminate the disclosure of:
- Components of investment return as both a separate disclosure and part of
the endowment rollforward
- The total performance of other investment portfolios that is currently
required for institutions of higher education.
Accounting
Write-Offs and Equity Transfers
The Board decided that the following
items should be reported separately from revenues, expenses, gains, and losses
and presented within the operating activity section of the statement of
activities and before the section of governing board transfers:
- The immediate write-off of goodwill upon an acquisition of an entity
(required of not-for-profit entities [NFPs] predominantly supported by
contributions and investment income), unless the acquired entity is for a
purpose or purposes that are not directed at carrying out the purpose for the
acquirer´s existence
- Accessions and deaccessions of noncapitalized collection items acquired
with resources that are without donor restrictions
- Equity transfers, unless they are not for current period use in carrying
out the purpose for the reporting entity´s existence.
The Board also
decided that NFPs should classify as operating cash flows their (1) cash
outflows for purchases of collection items, (2) cash inflows on the sale of
collection items, and (3) cash inflows for contributions received that are
restricted for the acquisition of collection items.
Governing Board
Designations
The Board decided to clarify that presentation of
governing board designations, appropriations, or similar transfers on the
statement of activities would include decisions made by the governing board´s
designees.
Proposed Transition and Effective Date and Comment Period
Length
The Board decided to require retroactive application of the
proposed changes. In the initial year of application of the proposed changes,
the annual financial statements would disclose the nature of any
reclassifications or restatements and their effect, if any, on the change in the
net asset classes for each year or period presented. Application to interim
financial statements would not be required in the initial year of application.
The Board also decided not to propose a specific effective date and will
instead ask respondents to provide information that would help the Board in
determining an appropriate date (or dates) during redeliberation.
The
Board also decided that, based on an expectation that the forthcoming Exposure
Draft would be issued by mid-April, the comment period would end on July 31,
2015.
Potential Benefits, Costs, and Complexities of the Proposed
Amendments
The Board discussed an analysis of the expected benefits
and perceived costs of implementing the proposed changes. The Board will
continue that discussion after its March 3, 2015 meeting with the Not-for-Profit
Advisory Committee (NAC).
Next Steps
The Board directed
the staff to discuss the summary of decisions reached at this meeting with the
NAC during its March 3, 2015 meeting. The Board will consider this feedback at
the March 4, 2015 Board meeting and decide whether (1) the overall expected
benefits of the proposed amendments justify the perceived costs and (2), if so,
to direct the staff to proceed with drafting a proposed Accounting Standards
Update.