7.2 Determining a Highly Inflationary Economy
ASC 830-10
45-11 The financial statements
of a foreign entity in a highly inflationary economy shall
be remeasured as if the functional currency were the
reporting currency. Accordingly, the financial statements of
those entities shall be remeasured into the reporting
currency according to the requirements of paragraph
830-10-45-17. For the purposes of this requirement, a highly
inflationary economy is one that has cumulative inflation of
approximately 100 percent or more over a 3-year period.
In determining whether it operates in a highly inflationary economy (i.e., one for which cumulative inflation is approximately 100 percent or higher over a three-year period), an entity may need to use judgment in addition to performing the cumulative inflation calculation. For example, when an economy’s cumulative inflation is approaching 100 percent, an entity must consider factors such as any relevant trends associated with the economy’s inflation rates. The Basis for Conclusions of FASB Statement 52 (codified in ASC 830) indicated that, in some cases, “the trend of inflation might be as important as the absolute rate” calculated in accordance with ASC 830-10.
However, this analysis is only necessary if an entity uses the highly inflationary economy’s currency as its functional currency. If another foreign currency is the functional currency, the entity is not considered to be operating in the local economy and therefore should only monitor the highly inflationary status of the economy related to its functional currency.
Example 7-1
Functional Currency Is Not the Local Currency of a Highly Inflationary
Economy
Company A is the subsidiary of a U.S.-based entity that is
physically located in Country V. Upon its acquisition by the U.S.-based entity
several years ago, A’s management determined its functional currency to be the
USD, and no significant changes in facts and circumstances have caused that
determination to change.
In the current year, V’s economy has been determined to be
highly inflationary. Because A does not use V’s local currency as its functional
currency, V’s designation as highly inflationary does not affect A’s accounting
records.
7.2.1 Calculating the Cumulative Inflation
ASC 830-10
45-12 The determination of a highly inflationary economy must begin by calculating the cumulative inflation rate for the three years that precede the beginning of the reporting period, including interim reporting periods. If that calculation results in a cumulative inflation rate in excess of 100 percent, the economy shall be considered highly inflationary in all instances. However, if that calculation results in the cumulative rate being less than 100 percent, historical inflation rate trends (increasing or decreasing) and other pertinent economic factors should be considered to determine whether such information suggests that classification of the economy as highly inflationary is appropriate. Projections cannot be used to overcome the presumption that an economy is highly inflationary if the 3-year cumulative rate exceeds 100 percent.
45-13 The definition of a highly inflationary economy is necessarily an arbitrary decision. In some instances, the trend of inflation might be as important as the absolute rate. The definition of a highly inflationary economy shall be applied with judgment.
45-14 Example 3 (see
paragraph 830-10-55-23) illustrates the application of
this guidance.
Example 3: Determination of a Highly Inflationary Economy
55-23 The following Cases
illustrate the application of paragraph 830-10-45-12:
-
The cumulative 3-year inflation rate exceeds 100 percent (Case A).
-
The cumulative 3-year inflation rate drops below 100 percent but no evidence suggests that drop is other than temporary (Case B).
-
The cumulative 3-year inflation rate drops below 100 percent after having spiked above 100 percent (Case C).
Case A: Cumulative 3-Year Inflation Rate Exceeds 100 Percent
55-24 Country A’s economy at the beginning of 19X9 continues to be classified as highly inflationary because the cumulative 3-year rate is in excess of 100 percent (see the following table). The recent trend of declining inflation rates should not be extrapolated to project future rates to overcome the classification that results from the calculation.
Case B: Cumulative 3-Year Inflation Rate Drops Below 100 Percent
55-25 Country B’s economy at the beginning of 19X9 should continue to be classified as highly inflationary even though the cumulative 3-year rate is less than 100 percent (see the following table) because there is no evidence to suggest that the drop below the 100 percent cumulative rate is other than temporary and the annual rate of inflation during the preceding 8 years has been high.
Case C: Cumulative 3-Year Inflation Rate Drops Below 100 Percent After Spike
55-26 Country C’s economy at the beginning of 19X9 should no longer be classified as highly inflationary because the cumulative 3-year rate is less than 100 percent (see the following table) and the historical inflation rates suggest that the prior classification resulted from an isolated spike in the annual inflation rate.
Although an entity may need to use some judgment in determining whether an
economy is highly inflationary, it should begin the determination by calculating the
cumulative inflation rate. As clarified in ASC 830-10-45-12, if the calculation (as
described below) “results in a cumulative inflation rate in excess of 100 percent, the
economy should be considered highly inflationary in all instances”
(emphasis added). Further, ASC 830-10-45-12 states — and the examples in ASC 830-10-55-24
through 55-26 illustrate — that projections of future inflation rates “cannot be used to
overcome the presumption that an economy is highly inflationary if the 3-year cumulative
rate exceeds 100 percent.”
An entity should perform this assessment in each reporting period for the three-year period ending as of the beginning of its current reporting period (including interim periods). For example, calendar-year-end entities with interim reporting requirements should calculate a cumulative inflation rate at the end of each quarter on the basis of the inflationary information for the past 36 months.
Once the three-year period has been identified, an entity should determine the
appropriate inflation rate or index to use for the cumulative-rate calculation. Although
ASC 830 does not specify which rates or indices should be used, general indices or rates,
such as those historically reported by the IMF or the Economist Intelligence Unit, are the
most common ones employed. The rates or indices used for the analysis should generally be
comprehensive (e.g., the comparable rate of the U.S. Consumer Price Index reported to the
IMF by foreign governments) rather than industry- or entity-specific. For detailed
instructions on obtaining inflationary information from the IMF’s Web site, see Section 7.2.2.
After identifying an appropriate rate or index, an entity must calculate the cumulative inflation rate for the most recent three-year period. ASC 830 does not specify whether period-end rates or average rates for the period should be used in the calculation of the cumulative inflation rate. In practice, entities may exercise judgment in selecting which method to use in calculating a cumulative rate as long as the method is applied consistently. Regardless of the method used, the FASB 52 Implementation Group concluded at its January 1982 meeting that the cumulative three-year inflation index should be calculated on a compounded basis (an annual rate of approximately 26 percent, when compounded, will result in a cumulative inflation rate of 100 percent).
The cases in ASC 830-10-55-24 through 55-26 illustrate how to calculate
cumulative inflation on a compounded basis. For example, the table below,
adapted from Case A in ASC 830-10-55-24, shows the annual rate and cumulative
three-year rate for the first three years.
In this scenario, an entity would perform the following steps in calculating the cumulative inflation rate on a compound basis:
In some cases, an annual index, rather than a specific inflation rate, is available. In such circumstances, an entity must perform the additional step of calculating the annual inflation rate for each year in the three-year period. The calculation of the cumulative inflation rate in such cases is illustrated in the table below.
Calculation of Cumulative Three-Year Rate by Using an Index
As noted in ASC 830-10-45-12, when the cumulative inflation rate is greater than
100 percent, the economy should be considered highly inflationary “in all
instances.” When the cumulative rate is less than 100 percent, an entity must
use judgment and carefully consider additional factors (e.g., trends). For
example, when an economy’s cumulative three-year rate has increased each year
and is approaching 100 percent, an entity should analyze whether this rate is
expected to reach 100 percent in the near future. Similarly, as illustrated in
the example in ASC 830-10-55-25, an entity would not automatically cease being
considered highly inflationary simply because the cumulative inflation rate
falls below 100 percent; rather, the entity should consider whether the decrease
is temporary.
7.2.2 Role of the IPTF
Previously, the IPTF had discussed inflation in certain countries at its semiannual joint meeting with the SEC staff. As reported in the November 21, 2017, joint meeting highlights, the IPTF concluded that ”it will no longer include [the inflation data] as a component of the semi-annual meeting with SEC staff, but rather it will generate a separate document to summarize the inflation data collected by the members of the IPTF.” The IPTF further indicated that the “document will not be reviewed by the SEC staff, however, the SEC staff has indicated that they are available for consultation should an entity wish to seek preclearance on its conclusions in this area.”
The IPTF developed a framework for compiling and presenting inflation data to
help entities monitor inflation statistics in certain countries whose economies
may be highly inflationary. Entities should consider the recent activities of
the IPTF when determining whether an economy is highly inflationary. However,
entities should not solely rely on the IPTF’s framework. Rather, they should
consider developing their own framework to monitor countries whose economies may
be highly inflationary, particularly if they have operations in multiple
countries. In addition, although information presented by the IPTF may be
helpful to making this determination, management should have appropriate
controls in place to independently monitor current reported inflation data as
well as to consider other economic indicators.
On May 21, 2019, the IPTF issued a discussion document, Monitoring Inflation in Certain Countries, which states, in part:
The Task Force compiled cumulative inflation data by country (for those countries for which the International Monetary Fund [IMF] publishes data), and then categorized the countries based on their cumulative inflation rates and the implementation guidance in ASC 830. . . . In addition, the Task Force identified countries where projected cumulative inflation rates would have been categorized into categories considering the guidance in ASC 830 and in circumstances where there was not consistent reliable data. The categories are . . . as follows:
1a. Countries with three-year cumulative inflation rates exceeding 100% (ASC 830, Case A)
. . .
1b. Countries with projected three-year cumulative inflation rates greater than 100% in the current year
. . .
2. Countries with three-year cumulative inflation rates exceeding 100% in recent years, but
with three-year cumulative inflation rates between 70% and 100%
in the last calendar year (ASC 830, Case B) . . .
3. Countries with recent three-year cumulative inflation rates exceeding 100% after a spike in inflation in a discrete period (ASC 830, Case C) . . .
4. Countries with three-year cumulative inflation rates between 70% and 100% in the current year, or with a significant (25% or more) increase in inflation during the last calendar year, or a significant increase in projected inflation in the current year, or with projected three-year cumulative inflation rates greater than 100% in the next year . . .
As the IPTF notes, ASC 830 provides examples illustrating several of the scenarios listed above. Specifically:
- Case A in ASC 830-10-55-24 provides an example in which the three-year cumulative rate exceeds 100 percent and in which a company must therefore classify the economy as highly inflationary.
- Case B in ASC 830-10-55-25 provides an example in which a country’s economy continues to be classified as highly inflationary even though the three-year cumulative rate is below 100 percent. The reason for this classification is that there is a lack of evidence suggesting that the drop below 100 percent is other than temporary and annual inflation has been consistently high.
- Case C in ASC 830-10-55-26 provides an example in which a country’s economy no longer exceeds 100 percent for the cumulative three-year rate and the classification as highly inflationary resulted from an isolated spike in annual inflation. ASC 830-10-55-26 indicates that this country’s economy should no longer be classified as highly inflationary.
The report includes countries that qualify for each of the categories listed in the discussion document. An example of a single country’s data, obtained from Category 1a, has been provided below. There may be additional countries that should be monitored that are not included in the IPTF report because the sources used to compile the IPTF list do not include inflation data for all countries or current inflation data.
As previously mentioned, although ASC 830 does not specify which rates or
indices should be used, those reported by the IMF are some of the most common
ones employed. In addition, we encourage entities not to rely solely on reports
such as those mentioned above to determine whether a country is highly
inflationary, particularly those entities with operations in multiple
countries.
Connecting the Dots
Inflation data is available on the IMF’s Web site. To access the data, an entity would perform the following steps:
- On the home page, click the “Data” tab.
- Select “World Economic Outlook [WEO] Databases” from the drop-down menu.
- Select the appropriate database, depending on the period for which an index or rate is needed.
- Select “By Countries (country-level data).”
- Select either the applicable country group and specific countries of interest or “All countries,” then click “Continue.”
- Under the “Monetary” header, select “Inflation, end of period consumer prices,” then click “Continue.”1
- Select a date range (e.g., 2014–2019) and click “Prepare Report.”
The IMF WEO report estimates inflation in instances in which actual inflation
data have not been obtained and describes the assumptions and methods used to
develop those estimates. The WEO report is generally released semiannually, and
the IMF data have limitations (e.g., the use of projected inflation data and
inconsistent dates through which actual data are included in the table may not
include certain indices). Nevertheless, the calculated three-year cumulative
inflation rates in the report are useful for determining which countries must be
further analyzed.
The IMF’s Web site indicates that historical information may be updated in the future as more information becomes available. Further, the information may differ from that reported by the respective countries’ central banks or governments (e.g., because a country has not reported inflation data to the IMF in a timely fashion). Accordingly, entities using the IMF data should consider whether they need to supplement such data with other pertinent information.
If an entity determines that such additional information is necessary, management may need to consider the applicable country’s central bank or government Web site to obtain annual or month-end inflationary information. When the presentation of such information differs from that used by the IMF to report the inflation data, the data may need to be converted because of differences in presentation (e.g., certain countries have recently reset their base index to 100).
Although the IMF rates are some of the most commonly used rates, an entity’s management may consider other sources of information. In fact, while the IPTF uses the IMF data to present inflationary data in its meeting minutes, the IPTF acknowledges that the Task Force does “not [perform] procedures to identify any potential differences” between the data used by the Task Force and “the inflation data reported by the respective countries’ central banks or governments.” The IPTF therefore suggests that the “summarized IMF information [be] supplemented, to the extent considered necessary, with other pertinent information that may be available.” Regardless of the data used, however, management must consider both the source and reliability of the information.
Connecting the Dots
Note that management is responsible for monitoring inflation and determining that an economy is highly inflationary. The IPTF discussion document states, “Registrants are responsible for monitoring inflation in countries in which they have operations.” To the extent that management’s conclusion regarding an economy’s highly inflationary status is inconsistent with inflation data provided by the IPTF, consultation with accounting advisers is strongly encouraged.
Footnotes
1
Note that both the index and the
percentage change may not be available and that the
report may have different information.