Key Dates

ASU 2021-10, Government Assistance (Topic 832) — Disclosures by Business Entities About Government Assistance (issued November 17, 2021)

Business entities (all entities except for not-for-profit [NFP] entities within the scope of ASC 958, Not-for-Profit Entities, and employee benefit plans within the scope of ASC 960, Plan Accounting — Defined Benefit Pension Plans, ASC 962, Plan Accounting — Defined Contribution Pension Plans, and ASC 965, Plan Accounting — Health and Welfare Benefit Plans) that account for a transaction with a government by applying a grant or contribution accounting model by analogy to other accounting guidance.

Annual periods beginning after December 15, 2021. Early application of the amendments is permitted.

ASU 2021-09, Leases (Topic 842 ) — Discount Rate for Lessees That Are Not Public Business Entities (issued November 11, 2021)

Lessees that are not public business entities, including all not-for-profit entities (whether or not they are conduit bond obligors) and employee benefit plans (whether or not they file or furnish financial statements with or to the U.S. Securities and Exchange Commission).

Entities that have not yet adopted ASC 842 as of November 11, 2021, are required to adopt the amendments in this ASU at the same time that they adopt ASC 842.

For entities that have adopted ASC 842 as of November 11, 2021, the amendments in this ASU are effective for fiscal years beginning after December 15, 2021, and interim periods within fiscal years beginning after December 15, 2022. Early application is permitted.

ASU 2021-08, Business Combinations (Topic 805) — Accounting for Contract Assets and Contract Liabilities From Contracts With Customers (issued October 28, 2021)

All entities that enter into a business combination within the scope of ASC 805-10, Business Combinations — Overall.

For public business entities, the amendments in this ASU are effective for fiscal years beginning after December 15, 2022, including interim periods within those fiscal years. For all other entities, the amendments are effective for fiscal years beginning after December 15, 2023, including interim periods within those fiscal years. The amendments in this ASU should be applied prospectively to business combinations occurring on or after the effective date of the amendments.

Early adoption of the amendments is permitted, including adoption in an interim period. An entity that early adopts in an interim period should apply the amendments (1) retrospectively to all business combinations for which the acquisition date occurs on or after the beginning of the fiscal year that includes the interim period of early application and (2) prospectively to all business combinations that occur on or after the date of initial application.

ASU 2021-07, Compensation — Stock Compensation (Topic 718): Determining the Current Price of an Underlying Share for Equity-Classified Share-Based Awards — a consensus of the Private Company Council (issued October 25, 2021)

All nonpublic entities that issue equity-classified share-based awards and elect the practical expedient in this ASU.

Effective prospectively for all qualifying awards granted or modified during fiscal years beginning after December 15, 2021, and interim periods within fiscal years beginning after December 15, 2022. Early application, including application in an interim period, is permitted for financial statements that have not yet been issued or made available for issuance as of October 25, 2021.

ASU 2021-06, Presentation of Financial Statements (Topic 205), Financial Services — Depository and Lending (Topic 942), and Financial Services — Investment Companies (Topic 946) — Amendments to SEC Paragraphs Pursuant to SEC Final Rule Releases No. 33-10786, Amendments to Financial Disclosures About Acquired and Disposed Businesses, and No. 33-10835, Update of Statistical Disclosures for Bank and Savings and Loan Registrants (issued August 9, 2021)

SEC registrants.

Effective upon issuance.

ASU 2021-05, Leases (Topic 842): Lessors — Certain Leases With Variable Lease Payments (issued July 19, 2021)

Lessors with lease contracts that (1) have variable lease payments that do not depend on a reference index or a rate and (2) would have resulted in the recognition of a selling loss at lease commencement if classified as sales-type or direct financing.

For public business entities, the amendments are effective for fiscal years beginning after December 15, 2021, and interim periods within those fiscal years. For all other entities, the amendments are effective for interim periods within fiscal years beginning after December 15, 2022. Earlier application is permitted.

Entities that have not adopted Topic 842 on or before the issuance date of this ASU should follow the transition requirements in 842-10-65-1. This transition is either (1) retrospective to each prior period presented in the financial statements with the cumulative effect of transition recognized at the beginning of the earliest period presented or (2) retrospective to the beginning of the period of adoption with a cumulative effect of transition recognized at the beginning of the period of adoption.

Entities that have adopted Topic 842 before the issuance date of this ASU have the option to apply the amendments in this ASU either (1) retrospectively to leases that commenced or were modified on or after the adoption of ASU 2016-02 or (2) prospectively to leases that commence or are modified on or after the date that an entity first applies the amendments.

ASU 2021-04, Earnings per Share (Topic 260), Debt — Modifications and Extinguishments (Subtopic 470-50), Compensation — Stock Compensation (Topic 718), and Derivatives and Hedging — Contracts in Entity's Own Equity (Subtopic 815-40): Issuer’s Accounting for Certain Modifications or Exchanges of Freestanding Equity-Classified Written Call Options — a consensus of the FASB Emerging Issues Task Force (issued May 3, 2021)

All entities that issue freestanding written call options that are classified in equity.

The amendments are effective for all entities for fiscal years beginning after December 15, 2021, including interim periods within those fiscal years. An entity should apply the amendments prospectively to modifications or exchanges occurring on or after the effective date of the amendments. Early adoption is permitted for all entities, including adoption in an interim period. If an entity elects to early adopt the amendments in this ASU in an interim period, the guidance should be applied as of the beginning of the fiscal year that includes that interim period.

ASU 2021-03, Intangibles — Goodwill and Other (Topic 350): Accounting Alternative for Evaluating Triggering Events (issued March 30, 2021)

Applies to private companies and not-for-profit entities that elect the accounting alternative.

These amendments are effective on a prospective basis for fiscal years beginning after December 15, 2019. Early adoption is permitted for both interim and annual financial statements that have not yet been issued or made available for issuance as of March 30, 2021. An entity should not retroactively adopt these amendments for interim financial statements already issued in the year of adoption.

ASU 2021-02, Franchisors — Revenue From Contracts With Customers (Subtopic 952-606): Practical Expedient (issued January 28, 2021)

All entities that are not public business entities that are within the scope of ASC 952.

If an entity has not yet adopted ASC 606, the existing transition provisions and effective date in ASC 606-10-65-1 are required. That guidance allows for an option of modified retrospective transition or full retrospective transition and an effective date of annual reporting periods beginning after December 15, 2019, and interim reporting periods within annual reporting periods beginning after December 15, 2020.

If an entity has already adopted ASC 606, the amendments in this ASU are effective in interim and annual periods beginning after December 15, 2020. Early application is permitted. For those entities, this guidance should be applied retrospectively to the date ASC 606 was adopted.

ASU 2021-01, Reference Rate Reform (Topic 848): Scope (issued January 7, 2021)

All entities that have derivative instruments that use an interest rate for margining, discounting, or contract price alignment that is modified as a result of reference rate reform.

Effective upon issuance.

ASU 2020-11, Financial Services — Insurance (Topic 944): Effective Date and Early Application (issued November 5, 2020)

All entities.

The amendments in this ASU defer the effective date of LDTI for all entities by one year as follows:

1. For public business entities that meet the definition of an SEC filer and are not SRCs, LDTI is effective for fiscal years beginning after December 15, 2022, and interim periods within those fiscal years.
2. For all other entities, LDTI is effective for fiscal years beginning after December 15, 2024, and interim periods within fiscal years beginning after December 15, 2025.

ASU 2020-10, Codification Improvements (issued October 29, 2020)

All entities.

The amendments in this ASU do not change GAAP and, therefore, are not expected to result in a significant change in practice. However, the Board is aware that some entities may have applied the guidance being amended in an inconsistent manner. The inconsistent application of the guidance may result in some entities changing their current accounting practices and financial statement reporting. Therefore, the Board is providing transition guidance for all the amendments in this ASU.

The amendments in Sections B and C of this ASU are effective for annual periods beginning after December 15, 2020, for public business entities. For all other entities, the amendments are effective for annual periods beginning after December 15, 2021, and interim periods within annual periods beginning after December 15, 2022.

Early application of the amendments in this ASU is permitted for public business entities for any annual or interim period for which financial statements have not been issued. For all other entities, early application of the amendments is permitted for any annual or interim period for which financial statements are available to be issued.

The amendments in this ASU should be applied retrospectively. An entity should apply the amendments at the beginning of the period that includes the adoption date.

ASU 2020-09, Debt (Topic 470): Amendments to SEC Paragraphs Pursuant to SEC Release No. 33-10762 (issued October 23, 2020)

SEC registrants.

January 4, 2021. Early application is permitted.

ASU 2020-08, Codification Improvements to Subtopic 310-20, Receivables — Nonrefundable Fees and Other Costs (issued October 15, 2020)

All entities.

The amendments affect the guidance in ASU 2017-08. The effective date of ASU 2017-08 varies depending on the type of entity. For public business entities, the amendments in ASU 2017-08 are effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2018, and for all other entities for fiscal years beginning after December 15, 2019, and interim periods within fiscal years beginning after December 15, 2020. Early adoption was permitted, including adoption in an interim period. If an entity early adopted the amendments in ASU 2017-08 in an interim period, any adjustments should have been reflected as of the beginning of the fiscal year that includes that interim period.

For public business entities, the amendments in this ASU are effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2020. Early application is not permitted.

For all other entities, the amendments in this ASU are effective for fiscal years beginning after December 15, 2021, and interim periods within fiscal years beginning after December 15, 2022. Early application is permitted for all other entities for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2020.

All entities should apply the amendments in this ASU on a prospective basis as of the beginning of the period of adoption for existing or newly purchased callable debt securities.

ASU 2020–07, Not-for-Profit Entities (Topic 958): Presentation and Disclosures by Not-for-Profit Entities for Contributed Nonfinancial Assets (issued September 17, 2020)

Not-for-profits that receive contributed nonfinancial assets.

The amendments in this ASU should be applied on a retrospective basis and are effective for annual periods beginning after June 15, 2021, and interim periods within annual periods beginning after June 15, 2022. Early adoption is permitted.

ASU 2020-06, Debt — Debt With Conversion and Other Options (Subtopic 470-20) and Derivatives and Hedging — Contracts in Entity’s Own Equity (Subtopic 815-40): Accounting for Convertible Instruments and Contracts in an Entity’s Own Equity (issued August 5, 2020)

Entities that issue convertible instruments and/or contracts in an entity’s own equity.

Effective for public business entities that meet the definition of a Securities and Exchange Commission (SEC) filer, excluding entities eligible to be smaller reporting companies as defined by the SEC, for fiscal years beginning after December 15, 2021, including interim periods within those fiscal years.

Effective for all other entities for fiscal years beginning after December 15, 2023, including interim periods within those fiscal years.

Early adoption is permitted, but no earlier than fiscal years beginning after December 15, 2020, including interim periods within those fiscal years. An entity should adopt the guidance as of the beginning of its annual fiscal year.

ASU 2020-05, Revenue From Contracts With Customers (Topic 606) and Leases (Topic 842): Effective Dates for Certain Entities (issued June 3, 2020)

All entities that have not yet issued their financial statements (or made their financial statements available for issuance) as of June 3, 2020.

Effective upon issuance.

ASU 2020-04, Reference Rate Reform (Topic 848): Facilitation of the Effects of Reference Rate Reform on Financial Reporting (issued March 12, 2020)

All entities.

The amendments in this ASU are effective for all entities as of March 12, 2020, through December 31, 2022.

ASU 2020-03, Codification Improvements to Financial Instruments (issued March 9, 2020)

All entities.

Conforming Amendments (Issues 1, 2, 3, 4, and 5)

The amendments related to Issue 1, Issue 2, Issue 4, and Issue 5 are conforming amendments. For public business entities, the amendments are effective upon issuance of this final ASU. For all other entities, the amendments are effective for fiscal years beginning after December 15, 2019, and interim periods within those fiscal years beginning after December 15, 2020. Early application is permitted.

The amendment related to Issue 3 is a conforming amendment that affects the guidance in the amendments in ASU 2019-04. That guidance relates to the amendments in ASU 2016-01 The effective date of ASU 2019-04 for the amendments to ASU 2016-01 is for fiscal years beginning after December 15, 2019, including interim periods within those fiscal years.

Amendments to ASU 2016-13 (Issues 6 and 7)

The amendments related to Issue 6 and Issue 7 affect the guidance in the amendments in ASU 2016-13. The effective date of ASU 2016-13 varies depending on the type of entity. Public business entities that meet the definition of an SEC filer, excluding eligible smaller reporting companies (SRCs) as defined by the SEC, should adopt the amendments in ASU 2016-13 during 2020. All other entities should adopt the amendments in ASU 2016-13 during 2023. Early adoption will continue to be permitted.

For entities that have not yet adopted the guidance in ASU 2016-13, the effective dates and the transition requirements for these amendments are the same as the effective date and transition requirements in ASU 2016-13.

For entities that have adopted the guidance in ASU 2016-13, the amendments are effective for fiscal years beginning after December 15, 2019, including interim periods within those fiscal years. For those entities, the amendments should be applied on a modified-retrospective basis by means of a cumulative-effect adjustment to opening retained earnings in the statement of financial position as of the date that an entity adopted the amendments in ASU 2016-13.

ASU 2020-01, Investments — Equity Securities (Topic 321), Investments — Equity Method and Joint Ventures (Topic 323), and Derivatives and Hedging (Topic 815): Clarifying the Interactions Between Topic 321, Topic 323, and Topic 815 — a consensus of the FASB Emerging Issues Task Force (issued January 16, 2020)

All entities.

The amendments in this ASU should be applied prospectively. Under a prospective transition, an entity should apply the amendments at the beginning of the interim period that includes the adoption date.

For public business entities, the amendments in this ASU are effective for fiscal years beginning after December 15, 2020, and interim periods within those fiscal years. For all other entities, the amendments are effective for fiscal years beginning after December 15, 2021, and interim periods within those fiscal years. Early adoption is permitted, including early adoption in an interim period, (1) for public business entities for periods for which financial statements have not yet been issued and (2) for all other entities for periods for which financial statements have not yet been made available for issuance.

ASU 2019-12, Income Taxes (Topic 740): Simplifying the Accounting for Income Taxes (issued December 18, 2019)

All entities.

For public business entities, the amendments in this ASU are effective for fiscal years, and interim periods within those fiscal years, beginning after December 15, 2020. For all other entities, the amendments are effective for fiscal years beginning after December 15, 2021, and interim periods within fiscal years beginning after December 15, 2022. Early adoption of the amendments is permitted, including adoption in any interim period for (1) public business entities for periods for which financial statements have not yet been issued and (2) all other entities for periods for which financial statements have not yet been made available for issuance. An entity that elects to early adopt the amendments in an interim period should reflect any adjustments as of the beginning of the annual period that includes that interim period. In addition, an entity that elects early adoption must adopt all the amendments in the same period.

ASU 2019-11, Codification Improvements to Topic 326, Financial Instruments — Credit Losses (issued November 27, 2019)

All entities.

For entities that have not yet adopted the amendments in ASU 2016-13 as of the issuance date of ASU 2019-11, the effective dates and transition requirements for the amendments are the same as the effective dates and transition requirements in ASU 2016-13.

For entities that have adopted the amendments in ASU 2016-13, the amendments in ASU 2019-11 are effective for fiscal years beginning after December 15, 2019, including interim periods within those fiscal years. Early adoption is permitted in any interim period after the issuance of ASU 2019-11 as long as an entity has adopted the amendments in ASU 2016-13.

For entities that have adopted the amendments in ASU 2016-13, the amendments in ASU 2019-11 should be applied on a modified retrospective basis by means of a cumulative-effect adjustment to the opening retained earnings balance in the statement of financial position as of the date that an entity adopted the amendments in ASU 2016-13.

ASU 2019-10, Financial Instruments — Credit Losses (Topic 326), Derivatives and Hedging (Topic 815), and Leases (Topic 842): Effective Dates (issued November 15, 2019)

All entities.

This ASU amends the effective dates of ASUs 2016-02, 2016-13, 2017-04, and 2017-12. See effective date information for these ASUs below.

ASU 2019-09, Financial Services — Insurance (Topic 944): Effective Date (issued November 15, 2019)

All entities.

This ASU amends the effective date of ASU 2018-12. See effective date information for ASU 2018-12 below.

ASU 2019-05, Financial Instruments — Credit Losses (Topic 326): Targeted Transition Relief (issued May 15, 2019)

All entities.

For entities that have not yet adopted ASU 2016-13, the amendments in ASU 2019-05 are effective at the same time as ASU 2016-13. For entities that have adopted ASU 2016-13, the amendments are effective for fiscal years beginning after December 15, 2019, including interim periods within those fiscal years.

Early adoption is permitted in any interim period after the issuance of ASU 2019-05 as long as an entity has adopted the amendments in ASU 2016-13.

The amendments in ASU 2019-05 should be applied on a modified-retrospective basis by means of a cumulative-effect adjustment to the opening balance of retained earnings balance in the statement of financial position as of the date that an entity adopted the amendments in ASU 2016-13.

ASU 2019-04, Codification Improvements to Topic 326, Financial Instruments — Credit Losses, Topic 815, Derivatives and Hedging, and Topic 825, Financial Instruments (issued April 25, 2019; effective date amended by ASU 2019-10)

All entities.

The amendments to ASU 2016-01 are effective for fiscal years and interim periods beginning after December 15, 2019.

For entities that have not yet adopted ASU 2016-13, the amendments are effective at the same time as ASU 2016-13. For entities that have adopted ASU 2016-13, the amendments are effective for fiscal years beginning after December 15, 2019, including interim periods within those fiscal years.

The amendments to ASU 2017-12 are effective (1) at the same time as ASU 2017-12 for entities that have not yet adopted the ASU, and (2) as of the beginning of the first annual reporting period beginning after April 25, 2019, for entities that have adopted ASU 2017-12.

Early adoption is permitted in any interim period after issuance of this ASU as long as the entity has adopted the amendments in ASU 2016-13.

ASU 2019-01, Leases (Topic 842): Codification Improvements (issued March 5, 2019)

All entities.

The transition and effective date provisions for ASU 2019-01 apply to Issue 1 and Issue 2. They do not apply to Issue 3 because the amendments for that Issue are to the original transition requirements in ASC 842.

The amendments in this ASU amend ASC 842, which has different effective dates for public business entities and entities other than public business entities. The effective date of those amendments is for fiscal years beginning after December 15, 2019, and interim periods within those fiscal years for any of the following: (1) a public business entity; (2) a not-for-profit entity that has issued, or is a conduit bond obligor for, securities that are traded, listed, or quoted on an exchange or an over-the-counter market; and (3) an employee benefit plan that files financial statements with the SEC.

For all other entities, the effective date is for fiscal years beginning after December 15, 2019, and interim periods within fiscal years beginning after December 15, 2020. Early application is permitted. An entity should apply the amendments as of the date that it first applied ASC 842, using the same transition methodology in accordance with ASC 842-10-65-1(c).

ASU 2018-20, Leases (Topic 842): Narrow-Scope Improvements for Lessors (issued December 10, 2018)

All entities.

For entities that have not adopted ASC 842, the effective date is the same as the effective date in ASU 2016-02.

An entity that has adopted ASC 842 can apply the amendments as of the original effective date of ASC 842 for the entity. Alternatively, the entity has the option of applying the amendments in either the first reporting period ending after the issuance of this ASU (e.g., December 31, 2018) or in the first reporting period beginning after the issuance of this ASU (e.g., January 1, 2019). An entity may apply the amendments either retrospectively or prospectively.

ASU 2018-19, Codification Improvements to Topic 326: Financial Instruments — Credit Losses (issued November 15, 2018)

All entities.

The effective date and transition requirements for the amendments in this ASU are the same as the effective dates and transition requirements in ASU 2016-13, as amended by ASU 2018-19.

ASU 2018-18, Collaborative Arrangements (Topic 808): Clarifying the Interaction Between Topic 808 and Topic 606 (issued November 5, 2018)

All entities.

For public business entities, the amendments in this ASU are effective for fiscal years beginning after December 15, 2019, and interim periods within those fiscal years.

For all other entities, the amendments are effective for fiscal years beginning after December 15, 2020, and interim periods within fiscal years beginning after December 15, 2021. Early adoption is permitted.

ASU 2018-17, Consolidation (Topic 810): Targeted Improvements to Related Party Guidance for Variable Interest Entities (issued October 31, 2018)

All entities.

For public business entities with fiscal years beginning after December 15, 2019, and interim periods within those fiscal years.

For private entities with fiscal years beginning after December 15, 2020, and interim periods within fiscal years beginning after December 15, 2021.

All entities are required to apply the amendments in this ASU retrospectively with a cumulative-effect adjustment to retained earnings at the beginning of the earliest period presented. Early adoption is permitted.

ASU 2018-16, Derivatives and Hedging (Topic 815): Inclusion of the Secured Overnight Financing Rate (SOFR) Overnight Index Swap (OIS) Rate as a Benchmark Interest Rate for Hedge Accounting Purposes (issued October 25, 2018)

All entities that elect to apply hedge accounting to benchmark interest rate hedges under ASC 815.

For entities that have not yet adopted ASU 2017-12, the amendments in ASU 2018-16 are required to be adopted concurrently with the amendments in ASU 2017-12.

For public business entities that have adopted the amendments in ASU 2017-12, the amendments are effective for fiscal years beginning after December 15, 2018, and interim periods within those fiscal years.

For all other entities that have adopted the amendments in ASU 2017-12, the amendments are effective for fiscal years beginning after December 15, 2019, and interim periods within those fiscal years. Early adoption is permitted in any interim period upon issuance of ASU 2018-16 if an entity already has adopted ASU 2017-12.

The amendments should be adopted on a prospective basis for qualifying new or redesignated hedging relationships entered into on or after the date of adoption.

ASU 2018-15, Intangibles — Goodwill and Other — Internal-Use Software (Subtopic 350-40): Customer’s Accounting for Implementation Costs Incurred in a Cloud Computing Arrangement That Is a Service Contract — a consensus of the FASB Emerging Issues Task Force (issued August 29, 2018)

Entities that are customers in a hosting arrangement that is a service contract.

For public business entities, the amendments in this ASU are effective for fiscal years beginning after December 15, 2019, and interim periods within those fiscal years. For all other entities, the amendments are effective for annual reporting periods beginning after December 15, 2020, and interim periods within annual periods beginning after December 15, 2021. Early adoption is permitted, including adoption in any interim period.

ASU 2018-14, Compensation — Retirement Benefits — Defined Benefit Plans — General (Subtopic 715-20): Disclosure Framework — Changes to the Disclosure Requirements for Defined Benefit Plans (issued August 28, 2018)

Employers that sponsor defined benefit pension or other postretirement plans.

For public business entities, the amendments in this ASU are effective for fiscal years ending after December 15, 2020. For all other entities, the amendments are effective for fiscal years ending after December 15, 2021. Early adoption is permitted.

ASU 2018-12, Financial Services — Insurance (Topic 944): Targeted Improvements to the Accounting for Long-Duration Contracts (issued August 15, 2018; effective date amended by ASU 2019-09 and ASU 2020-11)

All entities.

For public business entities that meet the definition of an SEC filer, excluding entities eligible to be smaller reporting companies as defined by the SEC, the amendments in this ASU are effective for fiscal years beginning after December 15, 2022, and interim periods within those fiscal years. For all other entities, the amendments are effective for fiscal years beginning after December 15, 2024, and interim periods within fiscal years beginning after December 15, 2025. Early application of the amendments is permitted.

ASU 2018-11, Leases (Topic 842): Targeted Improvements (issued July 30, 2018)

All entities.

The amendments in this ASU related to separating components of a contract affect the amendments in ASU 2016-02.

For entities that have not adopted ASC 842 before the issuance of this ASU, the effective date and transition requirements for the amendments in the ASU related to separating components of a contract are the same as the effective date and transition requirements in ASU 2016-02. For entities that have adopted ASC 842 before the issuance of this ASU, the transition and effective date of the amendments related to separating components of a contract in this ASU are as follows:

1. The practical expedient may be elected either in the first reporting period following the issuance of this ASU or as of the original effective date of ASC 842 for that entity.
2. The practical expedient may be applied either retrospectively or prospectively.

All entities, including early adopters, that elect the practical expedient related to separating components of a contract in this ASU must apply the expedient, by class of underlying asset, to all existing lease transactions that qualify for the expedient as of the date elected.

ASU 2018-10, Codification Improvements to Topic 842, Leases (issued July 18, 2018)

All entities.

The amendments in this ASU affect the amendments in ASU 2016-02. For entities that early adopted ASC 842, the amendments are effective upon issuance of ASU 2018-10, and the transition requirements are the same as those in ASC 842. For entities that have not adopted ASC 842, the effective date and transition requirements will be the same as the effective date and transition requirements in ASC 842.

ASU 2018-01, Leases (Topic 842): Land Easement Practical Expedient for Transition to Topic 842 (issued January 25, 2018)

Entities with land easements that exist or expired before an entity’s adoption of ASC 842, provided that the entity does not account for those land easements as leases under ASC 840.

The amendments in the ASU affect the amendments in ASU 2016-02, which are not yet effective but may be early adopted.

ASU 2017-13, Revenue Recognition (Topic 605), Revenue From Contracts With Customers (Topic 606), Leases (Topic 840), and Leases (Topic 842): Amendments to SEC Paragraphs Pursuant to the Staff Announcement at the July 20, 2017 EITF Meeting and Rescission of Prior SEC Staff Announcements and Observer Comments (issued September 29, 2017)

All entities.

Effective upon adoption of ASC 606, Revenue From Contracts With Customers, and ASC 842, Leases.

ASU 2017–12, Derivatives and Hedging (Topic 815): Targeted Improvements to Accounting for Hedging Activities (issued August 28, 2017; effective date amended by ASU 2019-10)

Public and private entities that elect to apply hedge accounting in accordance with current GAAP.

For public business entities, the amendments in the ASU are effective for fiscal years beginning after December 15, 2018, and interim periods within those fiscal years.

For all other entities, the amendments are effective for fiscal years beginning after December 15, 2020, and interim periods within fiscal years beginning after December 15, 2021.

Early adoption is permitted.

ASU 2017-04, Intangibles — Goodwill and Other (Topic 350): Simplifying the Test for Goodwill Impairment (issued January 26, 2017; effective date amended by ASU 2019-10)

All entities.

For public business entities that are SEC filers, excluding entities eligible to be smaller reporting companies as defined by the SEC, the amendments in the ASU are effective for annual and interim goodwill impairment tests in fiscal years beginning after December 15, 2019.

For all other entities, the ASU’s amendments are effective for annual and interim goodwill impairment tests in fiscal years beginning after December 15, 2022.

Early adoption is permitted for interim or annual goodwill impairment tests performed on testing dates after January 1, 2017.

ASU 2016-13, Financial Instruments — Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments (issued June 16, 2016; effective date amended by ASU 2018-19 and ASU 2018-10)

Entities holding financial assets and net investments in leases that are not accounted for at fair value through net income. The amendments affect loans, debt securities, trade receivables, net investments in leases, off-balance-sheet credit exposures, reinsurance receivables, and any other financial assets not excluded from the scope that have the contractual right to receive cash.

For public business entities that are SEC filers, excluding entities eligible to be smaller reporting companies, the amendments in the ASU are effective for fiscal years beginning after December 15, 2019, including interim periods within those fiscal years.

For all other entities, the amendments in the ASU are effective for fiscal years beginning after December 15, 2022, including interim periods within those fiscal years.

ASU 2016-02, Leases (Topic 842) (issued February 25, 2016; effective date amended by ASU 2019-10)

All entities.

Effective for fiscal years beginning after December 15, 2018, including interim periods within those fiscal years, for any of the following:

• Public business entities.
• Not-for-profit entities that have issued or are conduit bond obligors for securities that are traded, listed, or quoted on an exchange or an over-the-counter market.
• Employee benefit plans that file financial statements with the SEC.

For all other entities, the amendments in the ASU are effective for fiscal years beginning after December 15, 2020, and interim periods within fiscal years beginning after December 15, 2021. Early application of the amendments in the ASU is permitted for all entities.

SAS 145, Understanding the Entity and Its Environment and Assessing the Risks of Material Misstatement (issued October 2021)

Effective for audits of financial statements for periods ending on or after December 15, 2023.

SAS 143, Auditing Accounting Estimates and Related Disclosures (issued July 2020)

Auditors.

Effective for audits of financial statements for periods ending on or after December 15, 2023.

SAS 142, Audit Evidence (issued July 2020)

Auditors.

Effective for audits of financial statements for periods ending on or after December 15, 2022.

SAS 141, Amendment to the Effective Dates of SAS Nos. 134–140 (issued May 2020)

Auditors.

This SAS amends the effective dates of SASs 134–140 by one year to provide more time for firms to implement these SASs in light of the effects of the coronavirus pandemic.

SAS 140, Amendments to AU-C Sections 725, 730, 930, 935, and 940 to Incorporate Auditor Reporting Changes From SAS Nos. 134 and 137 (issued April 2020)

Auditors.

Effective for periods ending on or after December 15, 2021.

SAS 139, Amendments to AU-C Sections 800, 805, and 810 to Incorporate Auditor Reporting Changes From SAS No. 134 (issued March 2020)

Auditors.

Effective for periods ending on or after December 15, 2021.

SAS 138, Amendments to the Description of the Concept of Materiality (issued December 5, 2019)

Auditors.

Effective for audits of financial statements for periods ending on or after December 15, 2021.

SAS 137, The Auditor’s Responsibilities Relating to Other Information Included in Annual Reports (issued June 10, 2019)

Auditors.

Effective for audits of financial statements for periods ending on or after December 15, 2021. Early adoption is not permitted.

SAS 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA (issued July 10, 2019)

Auditors that perform audits of financial statements of employee benefit plans subject to ERISA.

Effective for audits of ERISA plan financial statements for periods ending on or after December 15, 2021. Early adoption is permitted.

SAS 135, Omnibus Statement on Auditing Standards — 2019 (issued May 8, 2019)

Auditors.

Effective for audits of financial statements for periods ending on or after December 15, 2021. Early implementation is permitted.

SAS 134, Auditor Reporting and Amendments, Including Amendments Addressing Disclosures in the Audit of Financial Statements (Issued May 8, 2019)

Auditors.

Effective for audits of financial statements for periods ending on or after December 15, 2021. Early implementation is permitted.

Adoption of Updated EDGAR Filer Manual (33-11043) (issued March 21, 2022)

Holding Foreign Companies Accountable Act Disclosure (34-93701) (issued December 2, 2021)

SEC registrants.

The amendments are effective on January 10, 2022, except for the addition of §232.405(c)(1)(iii)(C), which is effective from January 10, 2022, until July 1, 2023.

Universal Proxy (34-93596) (issued November 17, 2021)

SEC registrants.

Effective date: January 31, 2022.

Compliance date: The applicable compliance date is discussed in Section II.K.

Performance-Based Investment Advisory Fees (IA-5904) (issued November 4, 2021)

SEC registrants.

November 10, 2021.

Filing Fee Disclosure and Payment Methods Modernization (33-10997) (issued October 13, 2021)

SEC registrants.

Effective date: The final rules are effective on January 31, 2022, except for amendments to 17 CFR 202.3a, 17 CFR 230.111, 17 CFR 240.0-9, and 17 CFR 270.0-8, which are effective on May 31, 2022.

Compliance date: See Section II.A.6 for further information on transitioning to the final rules.

Adoption of Updated EDGAR Filer Manual, Form ID Amendments (33-10984) (issued September 20, 2021)

SEC registrants.

October 7, 2021.

Freedom of Information Act Regulations (34-92727) (issued August 23, 2021)

SEC registrants.

August 26, 2021.

Adoption of Updated EDGAR Filer Manual (33-10948) (issued June 21, 2021)

SEC registrants.

July 28, 2021.

Adoption of Updated EDGAR Filer Manual, Form ID Amendments (33-10935) (issued March 18, 2021)

SEC registrants.

Effective date: May 11, 2021. Incorporation by reference: The incorporation by reference of the EDGAR Filer Manual is approved by the Director of the Federal Register as of May 11, 2021.

Compliance date: The applicable compliance date is discussed in Section VII.

Investment Adviser Marketing (IA-5653) (issued December 22, 2020)

SEC registrants.

May 4, 2021.

Compliance Date: The applicable compliance dates are discussed in section II.K.

Exemption From the Definition of "Clearing Agency" for Certain Activities of Security-Based Swap Dealers and Security-Based Swap Execution Facilities (34-90667) (issued December 16, 2020)

SEC registrants.

April 2, 2021.

Market Data Infrastructure (34-90610) (issued December 9, 2020)

SEC registrants.

June 8, 2021.

Compliance Date: The applicable compliance dates are discussed in Section III.H, titled “Transition Period and Compliance Dates.”

Amendments to the Commission’s Rules of Practice (34-90442) (issued November 17, 2020)

SEC registrants.

The final rules are effective January 29, 2021, except for Instruction 8 which is effective July 12, 2021.

Compliance Date: Compliance with the amended rules is required on April 12, 2021 and is discussed further in Section III below.

Qualifications of Accountants (33-10876) (issued October 16, 2020)

SEC registrants.

June 9, 2021.

Compliance Date: See Section II.G for further information on transitioning to the final amendments.

Amendments to Procedures With Respect to Applications Under the Investment Company Act of 194034-89372 (IC-33921) (issued July 6, 2020)

SEC registrants.

June 14, 2021.

Securities Offering Reform for Closed-End Investment Companies (33-10771) (issued April 8, 2020)

SEC registrants.

Effective August 1, 2020, except that the amendments to rules 23c-3, 24f-2, and Form 24F-2 under the Investment Company Act and the amendments to rules 456 and 457 and Forms S-1, S-3, F-1, and F-3 under the Securities Act will become effective August 1, 2021. The applicable effective and compliance dates are discussed in section II.J.

Investment Company Reporting Modernization (33-10442) (issued December 8, 2017)

SEC registrants.

Effective January 16, 2018, until March 31, 2026. The effective date for the amendments to 17 CFR 232.401, 249.332, 270.8b–33, 270.30a–2, 270.30a–3, 270.30b1–5, and 17 274.130 and in Instructions 54, 57, 59, and 61 in the final rule published at 81 FR 81870 on November 18, 2016, is delayed until May 1, 2020.

Holding Foreign Companies Accountable Act Disclosure (34-91364) (issued March 18, 2021)

SEC registrants.

Effective on May 5, 2021.

Release 2021-004, Rule Governing Board Determinations Under the Holding Foreign Companies Accountable Act (issued September 22, 2021 and approved by the SEC on November 4, 2021)

Auditors of public entities.

Effective on the date of approval by the SEC — November 4, 2021.

Release 2020-003, Amendments to PCAOB Interim Independence Standards and PCAOB Rules to Align With Amendments to Rule 2-01 of Regulation S-X (issued November 18, 2020 and approved by the SEC on January 14, 2021)

Auditors of public entities.

Effective June 9, 2021, 180 days after the date of the publication of the SEC’s October 16, 2020, amendments to Rule 2-01 in the Federal Register. The June 9, 2021 effective date is aligned with the effective date of the SEC’s amendments to Rule 2-01. Auditors may elect to comply before the effective date at any point after SEC approval of the Board’s amendments, provided that the final amendments are applied in their entirety.

Statement 98, The Annual Comprehensive Financial Report (issued October 19, 2021)

Governmental entities.

Effective for fiscal years ending after December 15, 2021. Earlier application is encouraged.

Statement 97, Certain Component Unit Criteria, and Accounting and Financial Reporting for Internal Revenue Code Section 457 Deferred Compensation Plans (issued June 23, 2020)

Governmental entities.

The requirements of this Statement that (1) exempt primary governments that perform the duties that a governing board typically performs from treating the absence of a governing board the same as the appointment of a voting majority of a governing board in determining whether they are financially accountable for defined contribution pension plans, defined contribution OPEB plans, or other employee benefit plans and (2) limit the applicability of the financial burden criterion in paragraph 7 of Statement 84 to defined benefit pension plans and defined benefit OPEB plans that are administered through trusts that meet the criteria in paragraph 3 of Statement 67 or paragraph 3 of Statement 74, respectively, are effective immediately.

The requirements of this Statement that are related to the accounting and financial reporting for Section 457 plans are effective for fiscal years beginning after June 15, 2021. For purposes of determining whether a primary government is financially accountable for a potential component unit, the requirements of this Statement that provide that for all other arrangements, the absence of a governing board be treated the same as the appointment of a voting majority of a governing board if the primary government performs the duties that a governing board typically would perform, are effective for reporting periods beginning after June 15, 2021. Earlier application of those requirements is encouraged and permitted by requirement as specified within this Statement.

The Board considered the effective dates for the requirements of this Statement in light of the COVID-19 pandemic and in concert with Statement No. 95, Postponement of the Effective Dates of Certain Authoritative Guidance.

Statement 94, Public-Private and Public-Public Partnerships and Availability Payment Arrangements (issued April 20, 2020)

Governmental entities.

Effective for fiscal years beginning after June 15, 2022, and all reporting periods thereafter. Earlier application is encouraged.

May 25, 2022

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June 1, 2022

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June 6, 2022

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June 10, 2022

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June 13, 2022

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June 14, 2022

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June 17, 2022

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June 20, 2022

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June 28, 2022

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June 29, 2022

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June 30, 2022

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