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 July 2025, the FASB issued ASU 2025-05 to introduce a
practical expedient (for all entities) and an accounting policy
election (for non-PBEs that elect the practical expedient) that
apply to estimating credit losses on current accounts receivable
and current contract assets arising from revenue transactions
under ASC 606. See Section 5.2.3 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.
|
|
Certain purchased assets (Chapter
6)
|
ASC 326-20 contains provisions that
specifically apply to certain acquired financial assets —
namely, financial assets that are purchased after undergoing
credit deterioration (“PCD assets”) and acquired loans that are
deemed “seasoned” at acquisition (“purchased seasoned loans”
[PSLs]).
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 “gross-up” approach). The non-credit-related discount
or premium that results from acquiring a pool of PCD assets is
allocated to each individual financial asset.
In November 2025, the FASB issued ASU
2025-08, which expands the scope of
financial assets subject to the gross-up approach under ASC 326
to include certain PSLs, as defined in the ASU. ASU 2025-08 is
effective for annual reporting periods beginning after December
15, 2026, including interim reporting periods, and must be
applied prospectively. Entities may early adopt the guidance “in
an interim or annual reporting period in which financial
statements have not yet been issued or made available for
issuance.” An entity that adopts the amendments in an interim
reporting period may apply them “as of the beginning of that
interim reporting period or the beginning of the annual
reporting period that includes that interim reporting
period.”
|
|
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).1 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
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.