1.3 Key Provisions of ASC 326
The table below highlights some of the
key provisions of ASC 326 and includes links to sections of this Roadmap that discuss
these provisions in more detail.
Topic
|
Key Provisions of ASC 326
|
---|---|
Scope (Chapter 2)
|
ASC 326’s CECL model applies to:
AFS debt securities are outside the CECL model’s
scope (see Chapter 7 for discussion of the impairment model
for AFS debt securities).
|
Recognition threshold (Chapter
3)
|
None. Impairment is based on expected (rather than probable,
incurred) credit losses.
|
Measurement (Chapter 4)
|
Entities have flexibility in measuring expected
credit losses as long as the measurement results in an allowance
that:
The entity must evaluate financial assets on a
collective (i.e., pool) basis if they share similar risk
characteristics. If an asset’s risk characteristics are not
similar to those of any of the entity’s other assets, the entity
would evaluate the asset individually.
In December 2024, the FASB issued a
proposed ASU that would
introduce a practical expedient and accounting policy election
for private companies and certain not-for-profit entities. See
Section
9.2.2 for more information.
|
Application of the CECL model to off-balance-sheet commitments,
trade and lease receivables, and reinsurance receivables
(Chapter 5)
|
The CECL model affects off-balance-sheet
commitments and the accounting for assets commonly found at
nonbanks (e.g., certain trade and lease receivables and
reinsurance receivables) and includes guidance that an entity
should apply when accounting for such assets and
liabilities.
|
PCD assets (Chapter 6)
|
The allowance for PCD assets is the estimate of
CECL. Interest income recognition is based on the purchase price
plus the initial allowance accreting to the contractual cash
flows. The non-credit-related discount or premium that results
from acquiring a pool of PCD assets is allocated to each
individual financial asset.
On June 27, 2023, the FASB issued a
proposed ASU that would expand the model
for PCD assets to include all financial assets acquired in (1) a
business combination, (2) an asset acquisition, or (3) the
consolidation of a VIE that is not a business. The term PCD
asset would be replaced with the term PFA.1 See Section 9.2.1 for updates on this proposal.
|
AFS debt securities (Chapter
7)
|
The CECL model does not apply to AFS debt
securities. Provided that an entity does not have the intent to
sell an impaired AFS debt security and that it is not more
likely than not that the entity will be required to sell an
impaired debt security before its recovery, the entity will
recognize credit losses by using an allowance limited to the
difference between a debt security’s amortized cost and its fair
value.
|
Shortly before issuing ASU 2016-13, the FASB formed a credit losses
transition resource group (TRG).2 Although the group did not issue guidance, it provided feedback on potential
issues related to the implementation of the CECL model. By analyzing and discussing such
issues, the TRG helped the Board determine whether it needed to take action, such as
providing clarification or issuing additional guidance.
The FASB has continued its efforts to improve the CECL model. See
Chapter 9 for more
information about recent FASB activities.
Footnotes
1
AFS debt securities would be excluded
from the PFA model. In addition, for financial assets
acquired as a result of an asset acquisition or through
consolidation of a VIE that is not a business, the asset
acquirer would apply the gross-up approach to seasoned
assets, which are acquired assets unless the asset is
deemed akin to an in-substance origination. A seasoned
asset is an asset (1) that is acquired more than 90 days
after origination and (2) for which the asset acquirer
was not involved with the origination.
2
The TRG comprised financial statement preparers, auditors, and
users; FASB members also attended the group’s meetings. In addition,
representatives from the SEC, PCAOB, Federal Reserve, Office of the Comptroller
of the Currency (OCC), FDIC, National Credit Union Administration, and Federal
Housing Finance Agency were invited to observe the meetings.