15.1 Background and Objective
The disclosure objective of ASC 842 is to “enable users of financial statements to assess the amount,
timing, and uncertainty of cash flows arising from leases.” Accordingly, disclosures (both qualitative and
quantitative) are intended to supplement the amounts recorded in the financial statements so that
financial statement users can better understand the nature of an entity’s leasing activities from the
standpoint of both lessees and lessors.
Although disclosure requirements were also a critical aspect of ASC 840, users
believed that the information presented was often inadequate. ASC 842 therefore
contains expanded disclosure requirements that are significantly more comprehensive
than those in ASC 840. Accordingly, as with disclosures under the FASB’s revenue
recognition standard, disclosures about an entity’s leasing transactions are likely
to increase under the leasing requirements in ASC 842 even though they may have
decreased in many other areas of accounting (e.g., pensions, stock compensation,
fair value, and income taxes) because of the Board’s recent focus on reducing
disclosure overload (i.e., making disclosures more effective and coordinated and
less redundant).
The Board has therefore emphasized that entities need to remain focused on the
underlying disclosure objective so that they avoid obscuring useful information by
providing extraneous detail or losing relevance by furnishing significantly
aggregated information. Further, a “one-size-fits-all” approach would be
inconsistent with the disclosure objective of ASC 842; thus, to meet this objective,
it is critical that an entity use significant judgment and evaluate these
requirements against its own leasing activities.
Throughout ASC 842, the FASB consistently uses the word “shall” to indicate that
an entity would generally be required to provide a specific disclosure. However, in
paragraph BC276 of ASU 2016-02, the
FASB acknowledges that an entity needs to consider both relevance and materiality
when determining which disclosures to provide:
The Board also
rejected including an explicit statement that the disclosure requirements are
not required in all circumstances. That is because it is implicit to the overall
disclosure objective that the level of detail in the disclosures should equate
to the significance of an entity’s leasing activity (for example, if leasing is
a significant part of an entity’s business activities, the disclosures would be
more comprehensive than for an entity whose leasing activities are less
significant to its business activities).
For example, a lessee would most likely not discuss judgments and assumptions used to
allocate consideration in a contract between lease and nonlease components if there
are no nonlease components or if management concludes that the quantitative and
qualitative impact of the disclosure requirement is immaterial. However, as with
other materiality assessments, entities should carefully consider whether the
omission of a required disclosure represents an error. Entities are encouraged to
consult with their financial advisers when making such determinations.
Further, while the disclosures specified in ASC 842 are generally viewed as
mandatory, how an entity complies with these disclosure requirements may vary
significantly. An entity should assess which disclosures need to be provided for
each reporting period since a disclosure deemed irrelevant or immaterial in previous
reporting periods may subsequently become material (e.g., as a result of increases
in the monetary values to be disclosed or changes in qualitative factors).
Although the SEC staff has thus far issued relatively few comments on the application
of ASC 842, the staff has made certain observations related to this topic. For
example, registrants have received comments on (1) how ASC 842 applies or does not
apply in certain arrangements and (2) the discount rate used to calculate the amount
of the lease liability and corresponding ROU asset. Other topics addressed in SEC
staff comments on ASC 842 include, but are not limited to, the nature of expenses
treated as initial direct costs; the determination of lease classification;
accounting for leasehold improvements, including amortization; and impairment
considerations related to ROU assets. For further details about the staff’s
observations on each of these topics, see Deloitte’s Roadmap SEC Comment Letter Considerations, Including Industry
Insights.
As regulators review disclosures and issue comments, entities should evaluate their
peers’ filings and look for opportunities to improve existing disclosures. We
encourage such continual improvement and remind preparers to focus on the disclosure
objective stated above.
Connecting the Dots
System and Implementation Challenges
Entities should be proactive in developing the disclosures required by the standard because of
the substantive system and implementation challenges that may arise when entities (1) gather
the information necessary for drafting the required disclosures and (2) implement controls to
review related disclosures and underlying data.
This chapter is divided into the following overall subsections: