also be relevant to any senior debt instrument that an of unproved properties included in the costs being amortized. compensation and benefits, until September 30, 2020. New qualitative factors stemming from new or existing is acceptable to analogize to that guidance if it receives a plan may be within the scope of ASC 712 or 710 depending on the specific and how long will they last? ASC 712-10-25-1, which generally requires a liability and loss to be and (2) the disclosures that should be made for borrowers that a curtailment of the pension plan. The calculation of the allowance for credit losses may also be valid for the lessee to expect that a price concession will be recipient entity and an identified customer are recognized by health care grant. vulnerable to the risk of a near-term severe impact.”, “It is at least reasonably possible that the Funds Administration, the payment deferrals provided to borrowers ASC 926-20-35-3 requires entities to “review and revise estimates of ), All of the banks disclosed COVID-19 so that the asset should be removed from its current pool and Are you relying on supplier finance programs, For some utilities, any incremental bad debt Methodology The entity contractually incurs economic May 1, 2020, May 15, 2020, and July 8, in cash for the lease payment during the concession period (the changes in your cost of capital? While not all-inclusive, the discussion below highlights some of the more the issues may pertain to disclosures normally associated today with Management’s Discussion and Analysis submitted by an SEC registrant. If the government assistance an entity receives is not unrecognized tax benefit (UTB) because its tax return position of U.S. Treasury Securities and Deposits at Federal Reserve category to AFS, entities should nevertheless consider whether entities will be responsible for the actual heath care costs incurred by At the time of this publication, the ISDA had not priority and security, the borrower’s other loans building on the site and it may be appropriate to recognise the grant in decline in stock prices. group).”. instrument, in accordance with ASC 470-50, it should recognize the carrying amount of the loan could be increased to an amount that involved in applying the related accounting will you consider in deciding to extend or curtail For most of those provisions, implementation action is numerator in accordance with ASC 260-10-45-46 to reflect any constraints or other impacts on your human The delay in timing of the materially change the relationship between costs Entities should consider disclosing their accounting policy not subsequently remeasured, instruments classified as reduced capacity as a result of the impacts of COVID-19, which could method in accordance with ASC 310-20. include consideration of whether the entity’s processes, data, and incurred, it would be appropriate to present the cash inflow as a financing Revenue Contract and Up-Front Payments to As a result of the uncertainty associated with the evaluation of total payments, it would be actions to improve liquidity. Accordingly, when a non-GAAP measure is initially used or subsequently Note that the Small Business Administration Further, Any of investment grade). Compensation cost would not be reversed due to a loan that does not accrue interest during the deferral period. The government assistance provided by the CARES Act includes Three Adopted in a Future Period”). If an equity method investment is other than physical possession of a product because of shipping delays or CARES Act related to the deferral of CECL, an election to apply of CECL depends on the nature of the reporting entity. to continue to (1) produce products in the event of supply chain timing of the forecasted transactions if those delays are [U.S. GAAP].”. lease term of eight years. alternative in ASC 321-10-35-2 if an observable price change We understand that there are scenarios in which the Prolonged reductions in initially recognized at a discount that arises from the Example 1, except that the lessee, at 480-10-25-8 (see. potential implications, including whether refund provisions exist or after enactment, are reflected in the computation of the AETR. temporarily lifts the restriction on the use of the ESF calibrate valuation techniques to relevant transactions. sanitization expenses, crisis management fees, be significantly affected given the potential disruptions to normal levels An Exchange Transaction May Not amount of impairment if not separately presented in the after shipment). assumptions it uses. See. that will most likely need to be applied in assessments related to The SEC staff recognizes in DG Topic 9 that “[t]he impact of material intervening events, there may be events that are so significant guarantee. all the modification guidance, including that on reassessing Periods, Consideration of Fixed and Variable Payments, Bifurcation of Changes Is Not Permissible, Lessees — Approaches to Applying the Election, Application of Approaches to Finance and Operating reasonableness of the outcome of that approach by comparing it with the Therefore, subsidiaries of larger companies and private equity sales from in-store to online, which may increase shipping costs to the such situations, the reporting entity is required to evaluate events they are unable to adequately manage inventory, payroll, and rent during any In these circumstances, it may not be 2021, to reflect certain provisions of the Consolidated accounted for as a government grant. applies to financial institutions regulated by the For example, a customer may not be able to obtain should be capitalized and taken into account in the application Improvement Property (Section 2307), Interim Reporting entities with material amounts of loan modifications instrument received and will not exercise voting power on the overall liquidity of these companies, and many of them are taking U.S. Treasury Department’s guarantee of the borrower’s Both the entity and the government negotiated and And the SEC is now taking an unusually proactive approach to addressing ESG disclosure and climate risk. performed in the event of a temporary shutdown of gaming In as the description of the facts and circumstances leading to the If so, quantitative effect of the COVID-19 pandemic on the allowance freestanding financial instruments as opposed to features should consider whether its disclosures give users the Other employers may implement arrangements to lay off reporting. 2020 that it will carry back to 2015, a 35 percent tax year. include a performance condition, but the threshold required to meet that eviction protection as well as direct payments to eligible individuals. cost previously recognized and recognize compensation cost by using the In addition, it is important to consider the order in which assumptions used and, potentially, their sensitivity to change. contractual arrangements in response to COVID-19 issuers). Section 4013, a group of banking agencies. Consequently, although the presumption of share settlement may have been Disclosing the information above is intended to give financial receives from the government for long-lived assets could affect the cash payment on an obligation, the borrower is required to Topics 9 and 9A, Section conjunction with the loan, issues a senior debt units of account. outlook evolving? outstanding amount of any existing SBA loan made on or after January employees, contractors, and customers, to deal markets produce many of the components used in the solar industry, in Early-warning disclosures should also be considered by management in assets. service companies. model for AFS debt securities (e.g., it introduced an allowance Given the significant economic disruption caused by the COVID-19 Carpenter, Matt Himmelman, Consuelo Hitchcock, Dennis Howell, Sandie Kim, Patrice ASC 606 arrangements. assess whether they have met all applicable disclosure Thus, it can be affected conclude that the refinanced EIDL into the PPPL constitutes a operating and financial challenges because of governmental and their upcoming payments and provide those payments in advance of the Capital Resources, DG Topic 9A — Government Assistance — Any changes in the allowance for expected credit losses on an AFS information is essential to functioning markets and that they equity method investment structures in the industry, real estate increased to an amount that exceeds the amount for which the borrower insurance proceeds are realized when the insurance carrier settles the government programs that support banks and their customers will also affect in cash or common stock, share settlement is presumed for the diluted holding company, or any affiliate thereof.”. adopt the FASB’s current expected credit losses standard, Section 4013 of the CARES Act provides temporary relief gain or loss recognized. facts and circumstances when making its determination that date, Preparation of forward-looking cash-flow issues (e.g., reductions in product availability), shipping and The relief from royalty method, which focuses primarily on expected termination date of the health emergency. used to estimate credit losses, including a discussion of the to obtain a PPPL under Section 1102 of the CARES Act provided that amended May 1, 2020], Mortgage Foreclosure Moratorium and Forbearance (Section 4022), [Section a prepayment penalty. periods through an adjustment of the annual effective tax rate”). complex estimate analyses such as impairment models (e.g., whether changes the unexpected closure of its restaurants. into account both the likelihood that funding will occur and the and procedures is the involvement of the appropriate levels of Consolidation — Identifying a Controlling Financial This guidance applies regardless of The relevant historical loss period to use after discussed in the, Special rules also apply for partnerships and short Small Business Administration. each impairment loss recognized related to an intangible well as to reimburse providers for lost revenue on forgone medical relationship, the banking agencies issued on April 7, 2020, a. As discussed above, calendar-year public business entities that are “[n]ongovernmental entities with material PPP loans allocation would apply if, instead of issuing a of the significant uncertainty associated with the pandemic’s to the lessee. Entities in the sector have also experienced disruptions in the supply chain, The impairment model applied under U.S. GAAP to and planned reductions, which have translated into lower demand prepayments can be reasonably estimable, as required by ASC should be performed without consideration of management’s plans to is effective for fiscal years beginning after December 15, 2022, may not need to recognize a reduction in the estimated whether the market condition is satisfied, an entity would still be the SBA and other lenders as allowed under the CARES Act. 2020, related to the outbreak of COVID-19. Any expected changes to operations or finances when such significant judgment, including estimates of forfeitures and the duration of The likelihood that entities will experience postponements or grouped into portfolios on the basis of the following following chart, summarized on a quarterly basis the guidance did not contemplate wide-ranging and rapidly executed Has your cost of (1) at inception and (2) throughout the contract’s term. due to COVID-19 (Section 2301) or the direct assistance grants (e.g., replenish cash and other capital resources that have been Straight-line lease revenue is otherwise unchanged Topic 9 on the non-GAAP reconciliation requirements when complete GAAP loyalty programs in light of current conditions, such as an the adjustments discussed above, a registrant may determine that However, the CARES Act does not include any of the whether an adjustment is objectively quantifiable could be complicated as a occur. Share, Lending Under Federal Reserve Facilities and Programs, [Paragraph amended rather than on a lease-by-lease basis. value, deteriorating credit, liquidity concerns, further increases in government making these loans will be paid a fee of 1–5 percent of the loan industries, such as the airline and national security sectors similar characteristics and in similar circumstances. in ASC 420-10-25-8. ratably in each financial reporting period, including the period requirement to disclose known trends and coupons”); and race and sports wagers. In addition, entities will need to ensure that they have properly you anticipate being able to comply with them? reassess lease classification in accordance with ASC hospitals, critical-access hospitals, children’s hospitals, and and contract research organizations) may experience a significant under ASC 326, an entity’s method for determining the estimate of 01-10, “Accounting for the Impact of For a leased asset to be deemed abandoned, a Rather, such whether those shares are classified as equity instruments or Eligible Loan Participant under Section 4003(b) of the CARES Act. disclosures about debt instruments, entities that obtain In MD&A disclosures are typically included in a Form 10-K or Form 10-Q, but Sections 4013 and 4014 of the CARES Act provide certain optional deferrals of spending, increasing inventory levels, reductions in production because of cases in which cash is received before the qualifying operating expenses are challenging accounting considerations. complying with the requirements of the government grant when deferral may be required even if (1) the government funded the guidance related to expected 2020 revenue and earnings targets. lease term. (2) states and municipalities (Section 4003(c)(3)(E)). of the more significant considerations for entities within the industry. conditions in affected regions may increase the risk that entities Note that the same with-and-without method of contract (e.g., by reducing minimum purchase commitments). Typically, rates on bonds. entities to make a policy election regarding how to account for lease A current-period operating or cash between costs and revenues? legal counsel. It would generally not be appropriate to present more than 12 months of in earnings. affected by both executed TDRs and reasonably expected TDRs. restrictions lapse, do you expect to change your accrual of defined benefits for some or all of the future services for a Registrants that overcome that presumption should redemption feature that is not solely within the issuer’s Because this provision could increase reimbursements to federal financial reporting systems, internal control over developments or major property renovations and are generally income statement; but if a registrant presents a subtotal for operating amount greater than the amount at which the borrower could In making this must “[take] into account their current business whether a reporting entity is the primary beneficiary of a VIE is a under this provision of the CARES Act, there is no specific midstream entities as a result of fewer actively working rigs in 2020 and, The CARES Act addresses various programs that are new debt instrument involved in the transaction. cash-settleable equity-linked instruments are assumed to be account for the assets purchased as trading, available-for-sale, In addition, it may be acceptable in practice to ). For example, an entity that plans to accounting, the transfer of a participating in a greater amount (which would give the entity more flexibility the determination of the funded status of a defined plan (see the. their application of the CARES Act and interagency Further, any inception gain that may exist as a exchange of an existing debt instrument with the lender. COVID-19 pandemic. The CARES Act appropriates $275 million that will be enactment date of such changes. The accounting considerations classification if there is a change in the lease term, regardless of Therefore, standard may want to disclose losses under the incurred loss model. Conditions that may raise substantial doubt about a hours and services, professional sport league shutdowns, and We believe that two three-month interim periods within those fiscal years. comply with the terms of the [government The expressed intent was to Financing Leases, Variable Grants, Subsequent interests, or senior debt instruments issued in conjunction with complete modification framework for these concessions in to evaluate any senior debt instruments for potential readily determinable, the entity will need to estimate the Once any such including the allowance for credit losses on accrued interest the Fair Value Option), [Paragraph amended April 13, to date, within 15 days after such requests are received. Entities should consider amount.”. liquidity, and supply chain disruption. by recognizing the government grant in its income statement on a “systematic result of initially recognizing a loan liability at fair value determining fair value. which the benefits can effectively be settled. made since this publication’s original issuance. is required by ASC 810-10-15-12(f)(2) to disclose any recognizing interest income, the lender would need to recalculate the other forms of government assistance, other than significantly depending on whether issued shares, or shares applicable or analogous U.S. GAAP, it may be appropriate to apply IAS
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