AAPC: Accounting and Auditing Policy Committee

Leases Implementation

Request for CommentDue DateQuestions for
Comment LettersFinal Pronouncements
Leases Implementation Guidance Updates (PDF)June 30, 2023Word Version of QFRs (Download)Comment LettersN/A – Currently Under Due Process
Implementation Guidance for Leases & Omnibus Amendments to Leases-Related Topics: A Joint Exposure Draft (PDF)February 5,
Questions for Respondents (Download)Comment LettersImplementation Guidance for Leases (PDF)

FASAB Contact, Ricky A. Perry, Jr., perryra@fasab.gov

Project Objective

SFFAS 54, Leases, provides a comprehensive set of lease accounting standards to recognize federal lease activities in reporting entities’ general purpose federal financial reports and includes appropriate disclosures. The leases implementation guidance project is to provide timely guidance to ensure effective implementation of SFFAS 54. This project will clarify, explain, and elaborate on requirements of SFFAS 54.

Leases Implementation Task Force Meetings

September 6, 2019AgendaMinutes
October 4, 2019AgendaMinutes
January 28, 2020AgendaMinutes
April 15, 2020AgendaMinutes
May 12, 2020AgendaMinutes
June 11, 2020AgendaMinutes
July 29, 2020AgendaMinutes
February 22, 2021AgendaMinutes
March 2, 2021AgendaMinutes

Project History:

March 11, 2021

At the March AAPC meeting, the committee reviewed and discussed comment letters on the leases implementation guidance exposure draft. Staff presented proposed action items and recommended improvements in response to comment letters. The committee generally concurred with the staff- and task-force-developed action items.

Committee members provided feedback on certain implementation issues that require additional research and action, including: (1) further developing omnibus candidates and conforming changes to the technical guidance related to sale-leasebacks, (2) providing the Board with information related to certain implementation issues of which the Board should be made aware, and (3) implementing certain clarifying edits and changes discussed at the meeting. Committee members also discussed additional omnibus candidates identified by staff in response to comment letters and generally agreed with those candidates.

Staff will finalize omnibus recommendations for the Board’s April meeting and incorporate the feedback received from the committee on those items. The committee will discuss and seek to resolve a majority of these outstanding items at its May meeting, once staff has taken additional actions and received feedback from the Board.

October 21, 2020

At the October meeting, the Board reviewed and agreed upon finalizing edits to the pre-ballot draft of the leases omnibus proposal and the leases implementation guidance proposal previously approved for exposure by the AAPC.

The Board approved a ballot version of the leases omnibus proposal soon after the meeting. The adjoined exposure document, titled Implementation Guidance for Leases & Omnibus Amendments to Leases-Related Topics: A Joint Exposure Draft was released for public comment on November 2. The Board requests public comments by February 5, 2021. Staff will continue education and outreach efforts with the community and encourage stakeholders to review the proposals and provide comments.

Briefing materials – Tab B 

September 16, 2020

At the September AAPC meeting, the committee reviewed and discussed a pre-ballot draft of leases implementation guidance proposals. Staff presented outstanding items and resulting edits that stemmed from previously submitted and discussed comments from committee and/or task force members. The committee discussed additional edits and reached agreed-upon resolutions for resolving outstanding editorial and technical comments. The committee also discussed and revised questions for respondents and specific matters for comment to include in the joint exposure draft for purposes of obtaining important feedback from commenters.

August 12-13, 2020

At the August AAPC meeting, the committee reviewed and discussed a near-complete working draft of leases implementation guidance proposals. Committee members provided comments on aspects of the working draft over the course of the two-day meeting. The committee agreed to discuss outstanding items at the September meeting. The committee agreed with staff’s recommendation to exclude non-authoritative illustrations from the proposal, in the interest of completing the implementation guidance efficiently. Staff noted that non-authoritative illustrations could potentially be included in future staff implementation guidance at a later time. The committee also agreed to schedule a supplementary meeting on March 11, 2021, to review and discuss comment letters on the implementation guidance proposals after the public comment period.

May 7, 2020

At the May AAPC meeting, staff and the committee discussed a segment of working draft of leases implementation guidance proposals. Staff briefed members on recent AAPC task force proceedings and plans for reviewing future drafts at the August meeting. The committee decided to schedule a supplementary meeting on September 16 for purposes of approving the proposed implementation guidance to be released for public comment. The committee also agreed with staff’s recommended to expose the implementation guidance and the omnibus proposals in a joint exposure draft.

November 21, 2019

At the November AAPC meeting, staff and committee members discussed the status, approach, and timelines of the leases implementation guidance project. Staff briefed members on recent AAPC task force proceedings, including ongoing research to identify implementation issues and draft guidance.

The November AAPC issue papers can be found here.

August 28-29, 2019

Staff briefed the Board on the project plan for developing implementation guidance for SFFAS 54, Leases. Staff has, with the support of the Accounting and Auditing Policy Committee (AAPC) task force, undertaken a systematic process for identifying implementation issues by (1) performing a content analysis of analogous Governmental Accounting Standards Board implementation issues and (2) surveying task force members and their constituents regarding issue areas that may be candidates for guidance.

The task force roster is finalized, and meetings are scheduled for September 6 (completed), October 4, November 1, and December 6 (tentative).

Board members were generally supportive of the plan but observed that the timelines may prove challenging. Members asked that staff gather information from the task force regarding the present status of implementation efforts and return to brief the Board on the state of such at the October 2019 Board meeting.

Issue Paper for August 28, 2019 – Tab G (PDF)