EZ13 and Asset Retirement Obligations (ARO)

We are delighted to announce the release of a new module for our EZ13 Lease Accounting software. The new module tracks Asset Retirement Obligations. While primarily intended to be used for AROs tied to leases, it can also be used for AROs independently.

Asset Retirement Obligations are legal obligations of a company that take effect at the retirement of an asset. Most commonly, they are involved with restoring the asset to its original (pre-use) condition. One common example is cleanup of a drilling site by an oil/gas driller. Another applies to gas stations, which are required to dig up their underground fuel tanks when the station closes (or when the tank reaches the end of its useful life).

Under FAS 143, now called ASC Topic 410-20, a company must estimate the cost of the asset's retirement, most commonly by determining the current cost and applying an inflation factor to get the future cost. (Even if you expect to take care of the work using internal resources, the ARO must be priced based on hiring the work to be done; if you end up actually using internal resources, you will book a gain at that time.) It then books the present value of that cost (using its "credit-adjusted risk-free rate" for borrowing); the asset is called the Asset Retirement Cost, while the liability is the Asset Retirement Obligation. The ARC is depreciated over the remaining life of the asset, while the ARO is accreted over the same life; that is, an interest-type calculation is made on the liability using the same credit-adjusted risk-free rate, and the accretion expense is added to the liability, so that at the end of the asset's life, the ARO is equal to the expected (after-inflation) cost of retirement.

If you have a lease, the ARO's life is normally the same as the lease life. For an owned asset, the ARO life is typically the useful life of the asset itself.

EZ13 now offers complete ARO accounting as an extra-cost module. Reporting available includes showing ARO information on the income statement/balance sheet detail report, ARO accretion/depreciation tables, and rollforward reports (showing beginning balance, additions, accretion/depreciation, terminations, and ending balance, by lease). ARO components with varying levels of probability are accepted. For more details, including an example of an ARO calculation, please see our ARO page.

LWG favors level expense

Asset Finance International, a European website focused on equipment lessors, is reporting that yesterday's Leases Working Group meeting produced a strong consensus in favor of providing a level expense profile for most leases, as is currently the case for operating leases. While one of the arguments of IASB and FASB board members against this has been that it would mean a different depreciation methodology from owned property, plant, & equipment (PPE), one working group member turned that argument on its head, arguing that this profile would be more appropriate for both leases and owned assets. Obviously, rewriting depreciation rules for owned PPE is out of topic bounds, but changing the rules for leases could be a first step to "start getting it right."

As mentioned in my previous post, the staff presented five alternatives for lease expense profiles. Most LWG members preferred "interest based amortization," which basically subtracts the normally calculated interest expense from what level total expense for that period would be (total expense is generally equal to all rent paid over the life of the lease, which is then equally apportioned over the lease life). For a lease with a single rent step, this would mean that the depreciation per rent payment period would be essentially the same as the principal paid, so asset and liability would be equal throughout the life of the lease. If a lease has multiple rent steps, the difference between asset and liability would be the same as the deferred rent liability currently recognized on leveled operating leases. (The staff document only talks about a simple lease with one rent step; I'm not aware of anyone else pointing out this congruence with current operating lease accounting for multiple rent steps.)

Level expense recognition would not be applied to all leases. The LWG favored defining the dividing line between that and current finance/capital lease expense recognition more or less at the same point that current operating and capital leases are divided: a transfer of control or the lessee's control of "substantially all the remaining benefits" of the leased asset. The wording would be made as consistent as possible with another draft accounting standard on Revenue Recognition.

Level expense recognition would make transition to the new system easier. If all current operating leases are assumed to qualify, there would be no hit either to the income statement or to equity. However, the transition rules would need to be rewritten to specify how the balance sheet should be set up.

The next joint boards meeting is at the end of February, at which the expense profile will be on the agenda. Asset Finance International thinks that the new exposure draft can't come out before May even if the boards don't change the expense profile. If they do, it would likely take a few more months as they review the consequential changes to other parts of the standard. Add a four-month comment period and then time for the boards to redeliberate, and it's likely to be Q4 2012 or even 2013 before the final standard is finally released.

Leases Working Group meeting on expense profile

As previously noted, the FASB & IASB are reviewing whether a different expense profile would be appropriate for capitalized leases under the new proposed lease accounting standard. The current plan is for the same profile as for existing capital leases, which has more expense in the early months/years of a lease than at the end, because interest is recognized on the remaining principal balance, which declines over the life of the lease, while depreciation is normally recognized straight-line.

There is no joint FASB/IASB board meeting this month. However, tomorrow (Jan. 24) the Leases Working Group will meet with members of the boards. The LWG is a group of individuals from business, academia, and accounting firms who have an interest/specialty in lease accounting, who meet occasionally to provide feedback to the boards. Tomorrow's meeting will be primarily focused on the issue of the expense profile on lessee leases. Meeting papers are available here.

The boards' staffs have identified five alternatives for expense recognition:

(A) current approach
(B) modified interest-based amortization for the ROU (right of use) asset
(C) modified whole-asset
(D) use "other comprehensive income" to level the expense recognition
(E) allow current operating lease accounting for more leases

A brief description of each:

(A) As with current capital leases, interest expense is recognized on the outstanding liability (the "interest method") and depreciation is normally straight-line (officially, "reflecting the pattern of consumption of expected future economic benefits from use of the leased asset")

(B) Interest expense is the same; amortization is such that the interest plus amortization is equal for each reporting period. (For a lease with equal rent paid over its life, amortization each period would be equal to the reduction in principal.)

(C) Interest expense is the same; amortization is calculated by determining the net asset. The initial net asset is the fair value of the leased asset minus the present value of the expected residual value. The asset is depreciated and the residual value accreted over the life of the lease so that at expiration the two are equal.

(D) Interest and amortization are calculated like (A). Then the difference between that and the straight-line value is recognized in OCI (over the life of the lease, the OCI activity will net to zero).

(E) Current straight-line operating lease accounting would be used, with no ROU asset or lease liability recognized (though there would be a potential asset/liability for prepaid/accrued rent).

In addition to the question of whether any of the alternatives to (A) is preferable, there is the question of whether they should apply to all leases, or just a subset; if the latter, how should the target set be identified?

The working papers identify advantages and disadvantages to each approach, and show examples for simple equipment and land leases. (Some of them get much trickier to calculate with leases that have scheduled changes to the rent; no such examples are provided.)

The LWG will also discuss issues of investment property for lessors.

The boards will have their next joint meeting Feb. 27-29, and will presumably review these topics at that time.

December meeting results

The FASB & IASB met again to discuss leases on Dec. 13 & 14. Significant decisions reached include:

Cancellable leases
If both the lessee and the lessor have the right to cancel the lease (without termination penalties) such that the minimum term, including any non-cancellable period and any notice period, is 12 months or less, it meets the definition of a short-term lease. The key here is that either side can cancel; if one side can require renewal, then normal lease accounting applies.

Investment properties
Rental income from property accounted for (under IFRS 40) as investment property will not be capitalized, as such property is out of scope of the new leasing standard. However, the boards still chose how to recognize rental income: straight line, or another systematic basis if more representative of use of the asset.

Disclosures for these lessor leases are to include:

• Maturity analysis of future rents (at least 5 years by year, then the rest combined). This is not to be combined with the maturity analysis for capitalized leases.
• Separate entries for minimum contractual rents and variable lease payments
• Cost, carrying amount, and accumulated depreciation on leases
• Narrative information about lease arrangement

Future meetings
The staff listed the following items to be redeliberated:

• the definition of investment property (which is scoped out of this standard)
• the "lessee accounting model"--as mentioned in a Wall Street Journal article that I commented on previously, the boards are going to discuss further a way to recognize level expense over the life of a lease, even though they rejected this earlier
• additional disclosure items
  

November meeting results

Sorry, I'm behind again. This is from a month ago; I'll post the results of December's meeting as quickly as possible. This is from the FASB & IASB joint board meetings of Nov. 15 & 16, 2011:

Leases in business combinations
An acquired lessee lease is set up as if it is a new lease at the acquisition date, except that the asset is to be adjusted for any "off-market" terms in the lease; that is, if the rent due is substantially above or below market rents, the difference between market (present valued) and contract is folded into the asset.

This is a significant change from current accounting, which calls for a fair value calculation for both the asset and the obligation at the date of acquisition, with the result that the two are normally different at the acquisition date. Now the normal case will be equal asset and liability at acquisition, unless the rent is considered off-market.

An acquired lessor lease, using the receivable & residual approach, is set up as if it is a new lease at the acquisition date for purposes of calculating the receivable. The residual is the difference between the receivable and the fair value of the asset.

An acquired lessor lease that is treated as investment property or a short-term lease (originally or according to the remaining life at acquisition) is handled according to current rules under IFRS 3 and FASB Topic 805 for acquired operating leases. (However, I don't actually see anything explicitly talking about operating leases in Topic 805 or its original source, FAS 141, so I'm not sure what that means.)

Transition
If a lessee has a previously recognized intangible asset or liability to reflect (un)favorable terms in an operating lease, that should be folded into the right-to-use asset.

Currently, the sale of operating lease receivables by a lessor cannot be treated as a sale; instead, it is accounted for as a secured borrowing (because the receivable is not recognized on the balance sheet to begin with). The boards discussed whether to permit sale treatment at transition. Requiring it was seen as onerous; permitting it as an option would reduce comparability. The boards decided to permit it on a prospective basis only.

First-time adopters of IFRS generally would apply the same transitional rules as other companies, except that they are to use fair value determinations for a right-to-use asset.

Fighting on the expense profile

According to a Wall Street Journal article in yesterday's edition (available online only by subscription), most companies are resigned to the new lease accounting standard putting leases on the balance sheet. The primary issue they're pushing back on is the front-loading of expenses (which happens because interest is higher in the early years of a repayment schedule, while the depreciation remains straight-line throughout the lease term). The boards briefly considered, then rejected, a proposal earlier this year to make the expense profile straight-line by making the depreciation expense equal to the obligation repayment in each payment period; they didn't like the way the depreciation would look, and felt it was inconsistent with other aspects of accounting.

However, the topic hasn't died, and the article says that the FASB & IASB staff plan to revisit the issue with the boards, perhaps next month.

The article notes that the front-loaded profile is particularly problematic for retailers, who typically have lower revenues in the first years a store is open. Chains that are rapidly opening up new stores would be especially hard hit. The article indicates that investors also consider the expense front-loading unhelpful.

The article speculates that companies might shorten the life of their leases to reduce the impact of front-loading, but notes that that could cause problems for landlords who depend on long-term leases to guarantee their loans.

In other news, I realized I missed commenting on a November 1 meeting:

The boards worked through lessor disclosures, including:

• A table of all lease related income items, listing separately profit at lease commencement, interest income on the receivable, interest income on the residual, variable payments, and short-term lease income.
• Information about variable lease terms, renewal options, and purchase options
• A reconciliation of the right to receive payments and residual assets (showing beginning balance, additions, payments or residual accretion, terminations, and ending balance)
• A maturity analysis of future rent payments, by year for at least five years with the remainder as a lump sum
• Information about how the lessor manages risks on the underlying asset

The boards decided that a lessor doesn't need to disclose:

• Initial direct costs
• The weighted average or range of interest rates on leases
• "Fair values" of the receivable or residual (a term of art that requires determining a market price for sale)

Sale/leaseback transition

• An existing sale/leaseback transaction that resulted in a capital/finance lease will continue to be accounted for with no adjustments.
• A sale/leaseback with an operating lease or with no recognition of sale would be reevaluated based on the criteria for transfer of control of an asset in the proposed revenue standard (which presumably will be finalized no later than the leases standard; its exposure draft was put out Nov. 14). If met, the lease would transition like other operating leases.

Additionally, the FASB clarified that an exception from lease accounting under EITF 01-8, applicable to certain transactions entered into before May 2003, will not be retained, and such transactions will need to be accounted for as leases under the new standard.

This month's boards meeting

On Oct. 19, the FASB & IASB again met to discuss the new lease accounting standard. In a marathon session (scheduled for 5 hours), they reached a number of decisions in several areas. (Note: in the discussion below, and elsewhere in discussions about this standard, "effective date" is the date companies must start reporting under the new standard, while "date of initial application" is the date, normally two years earlier for U.S. companies, as of which leases must be treated as capital once the new standard takes effect, due to the requirement to restate years shown as comparables in the annual report.)

Lessee transition

• All existing capital leases will be carried over with no changes required. Previously, they had planned to require restatement of capital leases with variable payments or renewal options that would be treated differently under the new standard. They decided the benefit wasn't worth the cost, because in most cases the differences would be small (particularly given recent decisions to reduce recognition of variable payments and options).
• The incremental borrowing rate to use for operating leases to be capitalized will be a single company-wide rate, not based on the individual characteristics of each transitioning lease.
• Operating leases can be recalculated using either a "full" or a "modified" retrospective methodology. The same methodology must be chosen for all leases. Full means going back to lease inception and calculating the lease as capital. Modified is different from what was in the original Exposure Draft; I described it last month. They have clarified that the difference between asset and liability generated by this method is to be booked to retained earnings (no P&L impact).
• The simplifications ("reliefs") mentioned last month were all confirmed: leases that terminate before the effective date of the new standard won't have to be restated, even if they start after the date of initial application; initial direct costs are excluded during the same period; and preparers may use hindsight to set up the leases.

Lessor transition

• Capital leases other than leveraged leases can be carried over with no adjustments.
  
• Leveraged lease accounting is eliminated. Such leases will have to be restated.
• Current operating leases will have a receivable and residual set up using the present value of the rents and expected residual value at date of initial application, the interest rate being the rate charged in the lease as of lease inception; the underlying asset is derecognized. Lessors also have the option of full retrospective application.

Lessor receivables held for sale

• A proposal to report receivables held for sale at fair value was rejected. While this would superficially be consistent with IFRS 9 and the FASB's Accounting for Financial Instruments project, it was felt that it added complexity, was inconsistent with the rest of the leasing standard, offered opportunities for structuring, and would add more variability in profit and loss. Instead, any gain or loss would be recognized when a sale of the receivable is completed.

Variable payments for lessors

• If the rate a lessor charges a lessee assumes "reasonably assured" variable lease payments will be made, the residual asset (which by default contains the value of those payments, since the value is not in the receivable) will be adjusted by recognizing an adjustment to the residual. The adjustment is the variable lease payment divided by the fair value of the underlying asset, times its carrying amount.

Lessor receivable and residual

• Investment property is excluded from the lease standard scope. This keeps those properties under IAS 40 for companies using IFRS. The FASB is working on a project to create the same standard for the U.S. (which presumably will be complete by the time the lease standard takes effect).
• Profit on the residual will not be recognized until the asset is sold or re-leased.
• The residual is initially booked at the present value of the residual. The value is accreted, with interest income recognized for the accretion, using the same interest rate as for the receivable.