In 2014 the Financial Accounting Standards Board (FASB) began monitoring the global reference rate reform initiatives to determine appropriate alternatives to unsecured market benchmarks based on interbank offered rates. As a result of this monitoring initiative, the FASB and the Federal Reserve Bank of New York formed the Alternative Reference Rate Committee (ARRC) to aid in the identification of a suitable alternative to U.S. Dollar London Inter-bank Offer Rate (LIBOR) and to create a plan of adoption to alternative reference rates. This initiative resulted in the ARRC identifying the Secured Overnight Financing Rate (SOFR) as the alternative reference rate to be utilized. Once the ARRC determined the SOFR was a suitable alternative, the Federal Reserve Bank of New York started publishing a daily SOFR rate and announced a transition plan into financial markets in 2018.
This initiative to find a suitable replacement to LIBOR was a worldwide concern, which caused regulators around the globe to undertake reference rate reform initiatives to identify alternative reference rates that are transactional-based and less susceptible to manipulation. The FASB has undergone this process to largely consider changes to generally accepted accounting principles (GAAP) as a way to aid the market-wide transition from LIBOR and other interbank offered rates (collectively referred to as IBORs).
As part of the initiative, the FASB solicited feedback from various types of users in order to identify accounting issues related to the market-wide transition from IBORs. They cited the feedback received centered around two primary issues:
In order to address the two primary issues outlined above, the FASB faced several challenges. It was determined they needed to address the nature of the contracts requiring relief and the timing of issuance of guidance to correlate with contract modifications occurring in the normal course of business.
The nature of the contracts requiring relief, this hurdle is related to the extensiveness of expected modifications across the various types of contracts; for example, debt agreements, lease agreements, and derivative instruments. These instruments will need to be modified to replace the discontinued rates (e.g., LIBOR) with references to replacement rates (e.g., SOFR).
Timing of the proposed Accounting Standards Update (ASU) became a critical initiative of the FASB in order to allow companies to evaluate whether the modifications resulted in the establishment of a new contract or the continuation of an existing contract since the cost of implementing this accounting standard could be significant due to the large number of contracts being affected and the financial reporting results should reflect the intended continuation of these contracts and arrangements.
This ultimately correlates to the second accounting issue the FASB received feedback on. Feedback received noted the changes to reference rate reform could disallow the application of various hedge accounting guidance and some hedge relationships may not qualify as highly effective during the period of market-wide transition to a replacement rate, leading to financial reporting results of companies inappropriately reflecting hedging strategies when those strategies continue to operate as effective hedges.
Ultimately, the combination of the global market and FASB initiatives lead the FASB to issue a proposed ASU, “Referenced Rate Reform (Topic 848),” on Sept. 5, 2019. The proposed ASU will provide temporary optional guidance to alleviate the potential problems with accounting for and recognizing reference rate reform in financial reporting. The comment period for the proposed ASU ends on Oct. 7, 2019.
Primary provisions in the proposed ASU
As stated above, the amendments of the proposed ASU will provide only temporary optional expedient and exceptions for applying GAAP to contracts affected by referenced rate reform, if applicable criteria are met. Meaning only those contracts and hedging relationships which reference LIBOR or another reference rate will be discontinued upon implementation of reference rate reform.
Reference: “FASB InFocus – Reference Rate Reform” article dated Sept. 5, 2019
The proposed guidance outlines optional expedients aiding companies to reduce costs and accounting complexities of this reference rate reform. The primary expedients affected by reference rate reform are:
A company may elect to apply the amendments by electing the optional expedient for contract modifications applied consistently for all contracts or transactions within the applicable Topic, Subtopic, or Industry Subtopic, or elected on an individual hedging relationship.
Companies affected and effective dates
The proposed Update amendments are elective and apply to those companies who are subject to qualification criteria for contract modifications or hedging relationships which reference LIBOR or another reference rate affected by this rate reform.
The proposed amendment would be effective for all entities upon the issuance of a final Update. Upon adoption, an entity may elect to apply the proposed amendments prospectively to contract modifications made and to hedging relationships existing as of or entered into on or after the date of adoption and through Dec. 31, 2022. The proposed amendments would not apply to contract modifications made and hedging relationships entered into or evaluated after Dec. 31, 2022.
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