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FASB Projects Update – Spring 2015
Presentation to the American Petroleum Institute March 31, 2015
Mark Pollock, Practice Fellow
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This presentation has been prepared to help stakeholders understand the current status of the projects
discussed herein. The views expressed in this presentation are those of the presenter. Official positions of the
FASB and the IASB are reached only after extensive due process and deliberations.
Financial Instruments:
- Hedging
- Classification & Measurement
Disclosure Framework
Simplification Initiative
Projects on the Horizon
Agenda
2
Financial Instruments Hedging
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Timeline
FASB issued exposure drafts in June 2008 and May 2010 – focused on
targeted improvements to current hedging model in Topic 815 (FAS 133)
- No new Standard was issued
FASB issued a discussion paper in 2011 to obtain views on the IASB’s
proposed model at the time
IASB issued its final standard on the general hedge accounting model in
November 2013
Project moved from research to active status in November 2014
Project Status
4 4
Targeted improvements to Topic 815 rather than fundamental revisions
(similar to IFRS 9):
- Hedge effectiveness (quantitative vs. qualitative)
- Component hedging for nonfinancial items
- Application issues related to FV hedges of interest rate risk
- Potential elimination of shortcut and critical terms match
- Voluntary dedesignations
- Recording ineffectiveness for cash flow underhedges
- Potential simplifications to documentation requirements
- Presentation and disclosure
Project Direction
5 5
At the February 25, 2015 non-decision making Board Meeting two main approaches
emerged as possible changes to the hedge accounting model for nonfinancial items
Hedging Model for Nonfinancial Items
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Alternative Description
A An “alternative model” only for cash flow hedges of nonfinancial items
Move to a reasonably effective quantitative threshold (for example 50% to 200%)
Changes in fair value of derivative deferred to OCI as long as the hedged item and
hedging instrument maintain a reasonably effective relationship on a total price basis
When the hedged item affects earnings the amount in OCI related to the derivative
would be reclassed into the income statement line item hedged (i.e. COGS)
No hedge ineffectiveness would be recorded during the life of the hedge or at the
end of the hedge
B1 or B2 Retain the highly effective threshold in Topic 815 (80% to 125%)
Allow the hedged item to be a component of the overall total price, either:
o A contractually specified component (B1)
o B1 above or a component which is not contractually specified but for which it is
the market convention to use the component as an underlying basis for
determining the price of an overall product. Essentially a sub-component of a
contractually specified component (B2)
On Jan 1, 20X1 Airline Co. hedges a forecasted purchase of jet fuel with a crude oil futures contract.
Assume the purchase and subsequent use in operations of the jet fuel occur in the year ended 20X2.
Information related to the hedging relationship is as follows:
Jan 1, 20X1
Jet fuel spot price = $100/barrel
Jet fuel 1 year forward price = $110/barrel
Dec 31, 20X1
Jet fuel spot price = $150/barrel
Change in crude oil future = $50/barrel gain
Change in hypothetical “perfect” jet fuel derivative = $40/barrel gain
Example – Alternative A (reasonably effective threshold)
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Amount Line Item Details Amount Line Item Details
10.00$ Other Income Hedge ineffectiveness
40.00$ OCI Effective portion
Alternative A * 50.00$ OCIFull change in value of
derivative(100.00)$ COGS
$150 fuel cost less $50
derivative reclass
COGS(110.00)$ Current GAAP$150 fuel cost less $40
derivative reclass
Financial Statements
Year Ended Dec 31, 20X1
Financial Statements
Year Ended Dec 31, 20X2
*$50 change in value of derivative/$40 change in hypothetical = 125% offset. Derivative qualifies for hedge
accounting under current GAAP and Alternative A model and all “ineffectiveness” deferred into OCI. A
reasonably effective quantitative threshold is not yet defined but would be wider than today’s 80% - 125%.
Alternative A Observations
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Advantages Disadvantages
Relatively simple to apply
Preparers understand and have several years
experience performing quantitative tests of
hedge effectiveness on total price risk basis
Presents “full cost of hedging” in line item
hedged when the hedged item affects earnings
Easier for users to understand the effects of
hedging
Only works for hedging primary components
since effectiveness test carried out on total
price risk basis
No portfolio hedging since hedged item is
measured on a total price risk basis
Dual threshold between financial (highly
effective) and nonfinancial hedging (reasonably
effective) could create complexity or uneven
playing field
Deliberate “overhedge” could lead to artificially
high gross margins when the reclass of
derivative gain reduces cost of goods sold
Creating and valuing hypothetical derivative on
a total price risk basis could be difficult (same
as current GAAP)
On Jan 1, 20X1 ABC Co. hedges a forecasted purchase of 1,000 bushels of corn with a corn based derivative.
The purchase contract is structured as the CME spot price on 1/1/20X2 + transportation + taxes/fees.
Assume the purchase of corn and the sale of corn as inventory occur in the year ended 20X2. Information
related to the transaction is as follows:
Hedging Instrument Information
The change in the value of derivative was $1,040 loss as of 12/31/20X1
Effectiveness test done at component level. $5 ineffectiveness due to different settlement dates.
Example – Alternative B1 or B2 (Component Hedging)
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Total Price = Corn Component +
Transportation/Fees
Component
01/01/X1 $4,332.50 $4,242.50 $90.00
12/31/X1 $3,357.50 $3,207.50 $150.00
Change ($975.00) ($1,035.00) $60.00
Amount Line Item Details Amount Line Item Details
(65.00)$ Other Inc./(Exp.) Hedge ineffectiveness
970.00$ OCIEffective portion of change
in value of derivative
Alternative B (5.00)$ Other Inc./(Exp.) Hedge ineffectiveness
1,030.00$ OCIEffective portion of change
in value of derivative
(4,387.50)$ COGSPrice paid $3,357.50 and
reclass of OCI
COGS(4,327.50)$ Current GAAPPrice paid $3,357.50 and
relcass of OCI
Fianncial Statements
Year Ended Dec 31, 20X1
Financial Statements
Year Ended Dec 31, 20X2
Alternative B Observations
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Advantages Disadvantages
Component hedging better reflects risk
management strategy and objectives.
Constituents indicated treasurers view hedging
from a components and not total price perspective
Valuing hypothetical derivative on a commodity
component basis easier than on a total price risk
basis (don’t have to consider changes in
transportation, fees, taxes and other adders)
Works for any contractually specified component
regardless of what percentage of the total price
the item is (i.e. contractually specified fuel
component that is only 10% of total price)
Enables portfolio hedging of the same commodity
which cannot be hedged today or under
Alternative A because other aspects of the total
price (e.g. transportation) prevent portfolio
hedging.
Additional documentation that entity has
100% price risk to the component being
hedged
Potential that entities will invent pricing
formulas to get hedge accounting (Board can
put safeguards in place)
Identifying components could create
complexity or auditability issues
Works well for traded commodities with liquid
derivative markets earlier in the supply chain.
Finished goods are less likely to have a
contractually specified component linked to a
traded commodity
Financial Instruments
Classification & Measurement
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Changes to current GAAP Investments in equity securities
Measured at FV-NI, except for equity method investments
An entity (other than a broker dealer or an investment company) may
elect to measure equity securities without readily determinable fair
values at cost minus impairment, if any, plus or minus changes
resulting from observable price changes in orderly transactions for
the identical investment or a similar investment of the same issuer
- The entity cannot elect this option for equity securities that qualify to be measured
at NAV under Topic 820.
- These investments would be assessed for impairment at every reporting period
using a qualitative assessment
- The following disclosures would be required for these equity securities
Carrying amount, as well as the amount of the adjustments made to the carrying
amount due to observable price changes and impairment charges during the
reporting period
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Changes to current GAAP Financial liabilities measured under fair value option
The portion of the total fair value change resulting from a change in
entity-specific credit risk (own credit) would be presented separately
in other comprehensive income.
- An entity may consider the portion of the total FV change that exceeds the amount
resulting from a change in a base market rate (such as a risk-free) to be the result
of a change in entity-specific credit risk. Alternatively, an entity may determine the
effect of entity-specific credit risk by using another method it considers to more
faithfully represent that change.
- Required to disclose the method used to calculate the amount recorded in other
comprehensive income.
13
Changes to current GAAP Disclosures: FV of Financial Instruments not recognized at FV in Balance Sheet
An entity other than a public business entity would not be required to provide the incremental disclosures about fair value required by Section 825-10-50 (originally issued as FAS 107, Disclosures about Fair Value of Financial Instruments)
The following disclosure requirements would be removed from Section 825-10-50 - The method(s) and significant assumptions used to estimate the fair value of
financial instruments consistent with the requirements of paragraph 820-10-50-2(bbb)
- A description of the changes in the method(s) and significant assumptions used to estimate the fair value of financial instruments, if any, during the period
The fair values of financial instruments disclosed under the requirements of Section 825-10-50 should be determined in accordance with the guidance in Topic 820 (originally issued as FAS 157, Fair Value Measurements)
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Changes to current GAAP Disclosures: Hybrid Financial Instruments
Entities would be required to disclose the carrying amount,
measurement attribute, and line item within the balance sheet and
income statement in which bifurcated embedded derivatives and
related host contracts are presented
- This decision was exposed for public comments in 1Q 2015 (comment period will
end on April 30, 2015).
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Changes to current GAAP Disclosures: Other disclosures
Disclose in the notes all financial assets and financial liabilities
grouped by measurement category
- Financial assets would be further disaggregated by form of
financial assets (that is, security versus loan/receivable)
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Disclosure Framework
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Improving the effectiveness of notes requires both:
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Disclosure Framework: Two Components
Appropriate exercise of discretion by reporting entities when assessing disclosure requirements
Phase I: Board’s Decision Process
Phase II: Entity’s Decision Process
Consistent considerations by the
Board in each standard-setting
activity
Changes to Codification
Promoting Discretion
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Eliminate language that limits discretion
“Provide to the extent material”
Add guidance on applying materiality
Promoting Discretion (cont’d)
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US Supreme Court’s description
Omission not an accounting error
Applied individually and in the aggregate
Quantitative and qualitative
Guidance on Applying Materiality
Fair Value Measurement
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Disclosures provide information about:
• Ways an entity arrives at fair value • The effects on financial statements • Uncertainty in measurement • Measurement change period to
period
Objectives based on proposed framework
Disclosure Updates
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Sensitivity Information
Possible Changes to FVM
Forward-looking Information
Process and Policies
Gains and Losses
Rollforwards
Defined Benefit Plans
Fair Value Measurement
Income Taxes
Inventory
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Planned Exposure Drafts Q2
- Entity’s Decision Process
- Defined Benefit Plans
- Fair Value Measurement
Redeliberate Proposed Concepts in the
Disclosure Framework
Interim Considerations
Next Steps
Simplification Initiative
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Objective is to reduce cost and complexity while maintaining or improving the usefulness of the information
Projects would include narrow-scope items that the Board can complete in the short term
Welcome input on ideas
Simplification Initiative Objective
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Simplifying Income Taxes – Balance Sheet Classification of Deferred Taxes
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Presentation in a classified
balance sheet:
- Current deferred tax asset
and liability
- Noncurrent deferred tax
asset and liability
Classification:
- Based on classification of
related asset or liability
- Generally not classified
based on when the
temporary differences will
reverse
Classify all deferred tax assets
and liabilities as noncurrent
Current GAAP Solution
Simplifying Income Taxes – Intra-Entity Asset Transfers
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Buyer and seller defer the
recognition of income tax
consequences of an intra-
entity asset transfer until the
assets have been sold to an
outside third party
Exception to the accounting
model for comprehensive
recognition of income taxes
Eliminate the exception
Require recognition of the
income tax consequences of
an intra-entity asset transfer
when the transfer occurs
Current GAAP Solution
Simplifying Presentation of Debt Issue Costs
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- Debt issue costs presented
as deferred charge
- Discounts or premiums
presented as an adjustment
to debt balance
Debt issue costs presented
as an adjustment to debt
balance, consistent with
premiums or discounts
Current GAAP Solution
Simplifying Balance Sheet Classification of Debt
29
- Classification considers:
Debt covenants
Subjective acceleration
clauses
Revolving credit and lock-
box arrangements
Increasing rate debt
Debt due on demand
Callable debt
ST obligations expected
to be refinanced
Classify as noncurrent if one
or both of the following are
met at the balance sheet
date:
Debt is contractually due
more than 12 months after
the balance sheet date
Entity has a contractual
right to defer settlement
for at least 12 months
after the balance sheet
date
Current GAAP Solution
Simplifying the Measurement of Inventory
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Lower of cost or market
Measures for market value
include:
Replacement cost
Net realizable value
Net realizable value less
a normal profit margin
Inventory will be measured at
the lower of cost or net
realizable value
Reduce cost and complexity
of the subsequent
measurement
Maintain or improve the
usefulness of the information
required to be reported by an
entity
Current GAAP Solution
Projects on the Horizon
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Recently added to agenda: - Simplifying equity method accounting - Simplifying measurement period adjustments in business
combinations - Accounting for put / calls in debt (EITF) - Effect of derivative novations on hedge accounting (EITF) - Definition of a business
Potential: - Simplifying asset retirement obligations measurement
On the horizon
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Mark Pollock, FASB Practice Fellow
Mark is a Practice Fellow at the Financial Accounting Standards
Board (FASB) with 15 years of combined experience, heavily
focused on technical accounting and reporting matters. Prior to
joining the FASB staff, Mark was a Senior Manager in PwC’s
Assurance practice where he provided accounting and auditing
services to clients in the energy industry, including the exploration
and production, transportation and drilling services sectors. Mark is
also an alumni of PwC’s National Office where he specialized in the
accounting for financial instruments, such as leases, derivatives,
and debt / equity transactions.
Mark Pollock Practice Fellow
Financial Accounting Standards Board
401 Merritt 7, P.O. Box 5116, Norwalk, CT
06856
T: 203.956.3476 / Email: [email protected]
www.fasb.org