Implementing ASC 842 New Lease Accounting Proves Complex & Significant

A new leasing standard

The Financial Accounting Standards Board (FASB) issued its new leasing standard, Accounting Standards Update (ASU) No. 2016-02, Leases (ASC 842), in February 2016. It’s bringing $2 trillion of operating leases onto public company balance sheets, affecting the entities that enter into lease arrangements or sign contracts containing service agreements that support business operations. This was the FASB’s effort to require reporting of operating leases on balance sheets, in order to ‘increase transparency’ for investors and lenders.

Calendar year public companies adopted the standard in the first quarter of this year. Many found tracking and recording leases to be more time intensive than originally anticipated. About two-thirds of the public companies implementing the standard experienced difficulties in evaluating data and deploying software. Private companies, not-for-profit organizations, and smaller reporting companies had been scheduled to adopt the changes in 2020.

The effective date

But on the heels of the FASB receiving a letter from the AICPA’s Technical Issues Committee requesting a delay, the FASB voted unanimously July 17th to propose delaying the effective date until January 2021 for this group (many lack the resources to effectively handle adoption of the standard in a timely manner). As part of that July 17th meeting, the FASB also discussed whether it would be appropriate to provide longer delays on implementation dates for other companies, and whether smaller reporting companies should have deferred effective dates similar to private companies.

The FASB is considering allowing two years between the effective date for SEC filers and all other groups for future complex accounting updates. Before finalizing the new effective dates, the FASB issued a formal proposal for public comment with a 30-day comment period window ending September 16th. Once finalized, the new lease standard is expected to be effective for private companies for annual reporting periods beginning after December 15, 2020. This is a one-year deferral to the existing effective date.

A FASB board member said moving back the standard’s effective date for private and small reporting companies was about more than compliance. “They don’t have the resources, and if companies want to integrate the information into their business and use it for making business decisions in the future, they need more time.” There is difficulty in tracking down lease agreements and contracts across offices, in identifying embedded leases, and in putting together a transition strategy. The time and resources it takes to determine the impact on financial ratios and covenant compliance can easily be underestimated. Lease-versus-buy decisions may be impacted, and implementation may affect financial results.

Both aviation and rail equipment operators lease significant portions of their equipment under operating leases and related service agreements. They rely on operating lessors and often return equipment to the lessor at the end of the lease term with no residual value risk or exposure. The operating lessor, who retains the risks and rewards of ownership, then depends on equipment expertise and industry contacts to release, reconfigure, and/or trade equipment positions in order to cover their cost of capital and generate investment returns.

The AICPA has called lease accounting ‘significant and complex’. Similarly, maintaining a performing portfolio in today’s market faces unexpected hurdles. For solutions, call RESIDCO.