FASAB Contact, Melissa Batchelor, firstname.lastname@example.org, 202-512-5976
Technical Clarifications of Existing Standards (TCES) Project Description:
Members of the Board and the federal financial management community have expressed a general concern that federal entity resources are increasingly constrained. Some believe the Board should evaluate existing requirements and eliminate any unnecessary requirements. When appropriate, the Board explores opportunities to engage with the community on changes to existing standards and areas where clarification may be needed.
TCES addresses requests for guidance that align with the above goals and provide benefits that clearly exceed costs. To accomplish these goals, ongoing efforts may include providing additional forums for preparers, auditors, and users to identify requirements they believe are unnecessary and where clarification may be needed (this can be accomplished through an open-ended written request for input or round table discussions). The Board will assess requests against the reporting objectives. The Board may address these requests through the appropriate level of GAAP guidance.
Debt Cancellation Project Objective:
As part of the TCES project, this sub-project considers whether paragraph 313 of SFFAS 7, Accounting for Revenue and Other Financing Sources and Concepts for Reconciling Budgetary and Financial Accounting, which pertains to debt cancellation needs to be clarified.
The objective is to respond to a request for guidance from stakeholders by issuing clarifying guidance regarding debt cancellation as included in paragraph 313 of SFFAS 7. For example, the Board will clarify that debt cancellation activity should be reported on the statement of changes of net position.
HISTORY OF BOARD DELIBERATIONS
June 24 – 25, 2020
At the June 2020 meeting, the Board’s objective was to consider an updated draft Interpretation titled Debt Cancellation: An Interpretation of SFFAS 7 paragraph 313 and staff’s analysis of a proposal presented by the Department of the Treasury (Treasury) and the Office of Management and Budget (OMB). The project was not on the agenda in April 2020. Instead, staff provided the Board with a memo conveying an update regarding the debt cancellation issue. The memo was a means to provide the results of the research performed by Treasury and OMB as well as the outreach performed by FASAB staff. This memo is included with the June 2020 materials as attachment 6. In summary, neither the feedback obtained from the reporting entities affected by the recent debt cancellation nor the additional research regarding previous debt cancellations should impede or prevent the Board from moving forward on the project.
There were diverse comments and views expressed by members to the questions included in the April 2020 staff update. For example, as indicated in the June 2020 briefing materials, Treasury and OMB believe the Board should broaden the scope and revise the Interpretation to be consistent with their proposal. Certain members do not believe there is a need for FASAB action because they believe the standards are clear. Certain members are willing to move forward with an Interpretation if it can be done swiftly. In addition, certain members believe the circumstances are rare, and no action is required at this time because the Board can address the issue in a broader reexamination of existing standards project.
During the June 2020 meeting, the Board considered the Treasury and OMB proposal. The biggest difference is that their proposal provides flexibility with debt cancellation reported as a “budgetary financing source” or an “other financing source” on the statement of changes in net position (SCNP), whereas the staff proposal provides that debt cancellation would be classified as an “other financing source” on the SCNP.
Based on the basis for conclusions in Statement of Federal Financial Accounting Standards (SFFAS) 7, Accounting for Revenue and Other Financing Sources and Concepts for Reconciling Budgetary and Financial Accounting, FASAB staff does not believe the draft Interpretation should allow flexibility to recognize debt cancellation as either a “budgetary financing source” or an “other financing source” on the SCNP. Paragraphs 209-212 in SFFAS 7discuss the budgetary process and its linkage to accounting. Footnote 43 to paragraph 212 states, “Amounts appropriated to liquidate contract authority or repay debt are not available to incur new obligations and hence are not considered new budget authority.” Likewise, debt cancellation activity would not be considered new budget authority or a budgetary financing source. Debt cancellations should be classified as an “other financing source” on the SCNP, whether an appropriation was received or not.
FASAB staff does not believe the suggested flexibility in the Treasury/OMB proposal would resolve the issue presented in the Interpretation. Further, it is not supported by the basis for conclusions of SFFAS 7.
The Board discussed issuing the draft Interpretation through paragraph 9, so it would provide clarity and guidance on the issue regarding gain/loss as it relates to debt cancellation. However, there was concern whether those paragraphs would resolve what the issue.
FASAB staff did not believe issuing an Interpretation through paragraph 9 would fully resolve the debt cancellation issue that occurred in fiscal year 2018 at the Department of Homeland Security (DHS) and resulted in the material weakness. The remaining paragraphs were necessary to address the issue pertaining to the classification on the SCNP.
The Board agreed to give Treasury an opportunity to revisit the specifics with the agencies to confirm the issues.
The chair polled the members to see if they supported the Treasury proposal to issue the draft Interpretation through paragraph 9—providing guidance on the issue regarding gain/loss as it relates to debt cancellation. However, staff noted that this abbreviated Interpretation would not fully resolve the issue The Board agreed with the Treasury request to revisit the issue with all parties—FASAB staff, DHS, Treasury, and auditors—to discuss whether the draft Interpretation through paragraph 9 would resolve the issue. The Chairman noted that it is very important to ensure the guidance would resolve a problem.
The Board agreed to Treasury’s short-term proposal to issue the draft Interpretation through paragraph 9 if it will resolve the debt cancellation issue. Treasury and FASAB staff will meet with all parties—DHS, Treasury deputy chief financial officer, and auditors to ensure the draft Interpretation through paragraph 9 will fully resolve the debt cancellation issue that existed.
Considering the Board’s goal that work on the limited scope project be accomplished without significant additional resources, FASAB staff will consider if lower level GAAP guidance may be appropriate.
Briefing materials – TAB B
February 26-27, 2020
At the February 2020 Board meeting, the Board considered an initial staff draft, Debt Cancellation: An Interpretation of SFFAS 7 paragraph 313. The Board first discussed paragraph 313 of Statement of Federal Financial Accounting Standards (SFFAS) 7, Accounting for Revenue and Other Financing Sources and Concepts for Reconciling Budgetary and Financial Accounting, at the October 2019 Board meeting and agreed that an Interpretation would be used at the December 2019 meeting.
The Board agreed to allow time for additional research request by the two members and requested that staff consult with the reporting entities affected by the recent debt cancellation to determine whether staff’s draft Interpretation would have resolved the issues.
The Board agreed to delay further consideration of the debt cancellation exposure draft (ED) pending research into prior debt cancellations and other historical circumstances.
February 26-27, 2020 – Tab G (PDF)
December 17-18, 2019
At the December 2019 meeting, the Board considered two potential Interpretation topics under the evaluation of existing standards project.
At the October 2019 meeting, the Board had agreed that paragraph 313 of SFFAS 7, Accounting for Revenue and Other Financing Sources and Concepts for Reconciling Budgetary and Financial Accounting, which pertains to debt cancellation, needed clarification.
The Board agreed that the terms “gain and loss” as used in paragraph 313 need clarification or an explanation that those terms are not required for presentation. It is important to clarify that debt cancellation activity is reported on the statement of changes in net position. An Interpretation will be used to clarify these items. A member requested that a question be included in the exposure draft (ED) that requests feedback on whether the proposed Interpretation resolves ambiguity that may exist in paragraph 313 and provides the necessary clarification.
The Board also agreed that SFFAS 1, Accounting for Selected Assets and Liabilities, paragraph 31, which pertains to non-entity fund balance with Treasury (FBWT), required clarification. The issue relates to how monies received in deposit funds from non-federal sources in anticipation of an order should be reported and presented on the financial statements. The Board agreed that an Interpretation would be the appropriate generally accepted accounting principles vehicle to address the SFFAS 1, paragraph 31 non-entity FBWT issue.
Issue Paper for December 17-18, 2019 – Tab B (PDF)
October 23-24, 2019
The Board considered whether paragraph 313 of SFFAS 7, which pertains to debt cancellation, needs to be revised. Messrs. Soltis and Bell requested that FASAB review paragraph 313 of SFFAS 7 because they believed there may be a disconnect in requirements related to debt cancellation. This is based on an issue raised during the FY 2018 audit cycle.
The Board agreed that fundamentally paragraph 313 is accurate, but it may be the imprecision of the terms “gain/loss” that is the issue. The Board also discussed that a presentation issue may exist and may be related to how U.S. Standard General Ledger accounts roll up to the statement of changes in net position. The Board believed it may be important to clarify that the categorization or captioning is not important as long as it is on the statement of changes in net position.
The Board agreed that the issue regarding debt cancellation required generally accepted accounting principles (GAAP) clarification. Specifically, the guidance would clarify that debt cancellation is reported on the statement of changes in net position but need not be presented as a specific “gain/loss” line item. The guidance would also provide for enhanced disclosures as appropriate.
Most Board members agreed that the issue should be resolved with the lowest level of GAAP guidance afforded. The Board will consider options at the next Board meeting.
Issue Paper for October 23-24, 2019 – Tab H (PDF)