Omnibus Amendments
For questions about this project, email omnibusamend@fasab.gov.
| Request for Comment | Due Date | Word Version of questions for Respondents | Comment Letters | Final Pronouncements |
|---|---|---|---|---|
| Omnibus Amendments: Amending SFFASs 38, 49, and Technical Bulletin 2011-1 (PDF) | September 21, 2023 | Word Version of Questions for Respondents (Download) | Comment Letters | Omnibus Amendments 2024-1: Amending Statements of Federal Financial Accounting Standards 38, 49, and Technical Bulletin 2011-1 (PDF) |
Project Objective:
The objective of the omnibus amendments project is to amend multiple provisions through a single action. The Board expects the amendments to be narrow in scope and not to create new requirements for reporting entities. Also, combining proposed amendments should ease the burden on respondents as well as make efficient use of Board time. The omnibus amendments project targets miscellaneous, narrowly-focused updates to various Statements.
History of Board Deliberations (reverse chronology)
April 12, 2024
On April 12, 2024, FASAB issued SFFAS 63, Omnibus Amendments 2024-1: Amending SFFAS 38, 49, and Technical Bulletin 2011-1. SFFAS 63 retains the reporting of federal oil and gas and other natural resource information as required supplementary information per SFFAS 38, Accounting for Federal Oil and Gas Resources, and Technical Bulletin (TB) 2011-1, Accounting for Federal Natural Resources Other than Oil and Gas. The Statement also eliminates an exception provided in SFFAS 49, Public Private Partnerships: Disclosure Requirements, to avoid reporting inconsistencies and to increase comparability.
January 2024
The Board voted to approve the release of proposed Statement of Federal Financial Accounting Standards (SFFAS) 63: Omnibus Amendments 2024-1, Amending Statements of Federal Financial Accounting Standards 38, 49, and Technical Bulletin 2011-1. The proposed SFFAS 63 was sent to sponsors for review on January 12, 2024. If no objection is received by April 11, 2024, SFFAS 63 will be issued on April 12, 2024.
December 12-13, 2023
At the December 2023 meeting, members reviewed the pre-ballot version of the proposed omnibus amendments with the additional clarifying edits to paragraph 24b of SFFAS 49, Public-Private Partnerships, and the related footnotes and basis for conclusions. These edits address the use of estimates for disclosing the mix and amount of private partner funding. Additionally, members discussed removing texts that may be vague or confusing. After deliberating and making changes, members agreed to move forward with the final ballot on proposed SFFAS 63: Omnibus Amendments 2024-1: Amending Statements of Federal Financial Accounting Standards 38, 49, and Technical Bulletin 2011-1.
Briefing Materials – Topic C
October 17-18, 2023
At the October 2023 Board meeting, members reviewed comment letters on the exposure draft titled Omnibus Amendments: Amending Statements of Federal Financial Accounting Standards 38, 49, and Technical Bulletin 2011-1. Members agreed to move forward with the proposed amendments to Statement of Federal Financial Accounting Standards (SFFAS) 38, Accounting for Federal Oil and Gas Resources, and Technical Bulletin 2011-1, Accounting for Federal Natural Resources Other Than Oil and Gas, to retain information on oil, gas, and other natural resources as required supplementary information.
Members also reviewed amendments to paragraph 24b of SFFAS 49, Public-Private Partnerships: Disclosure Requirements.
Staff provided an overview of the fundamental problem precipitating the proposed amendments to address the “where available” exception in paragraph 24b of SFFAS 49. As reported to staff and the task force, certain preparers and their auditors have used the exception as a basis to not disclose, specifically, the remote risks underlying the public-private partnerships (P3) arrangement/transaction as required by the standards. Their rationale is that the Board’s logic in paragraph 24b is in essence allowing an exception whenever any disclosure element is not available.
Staff noted that most of the respondents, including preparers, agreed that the “where available” exception or “loophole” should be addressed to avoid exploitation. To that end, some respondents noted that the Board should consider making it more difficult to avoid disclosure of private partner funding amounts and clearly note that the paragraph 24b exception could not be used to avoid reporting any other paragraph 24 disclosure requirement. To the contrary, other respondents were in support of the proposed amendment and argued against the retention of the “where available” exception even if accompanied by language that would lessen its use and prohibiting its application elsewhere.
Staff reminded members that (1) the Board intended providing preparers with flexibility concerning private partner funding amounts for those instances when the entity would be legally or contractually prohibited from disclosing said amounts, (2) Statement of Federal Financial Accounting Concepts 1, Objectives of Federal Financial Reporting, states reliability does not imply precision or certainty and that estimates are appropriate for reporting, and (3) several Office of Management and Budget documents require full lifecycle reporting and, specific to P3s, assessments of private partner participation for budget scoring purposes.
Members then discussed both reasons for and against the “where available” exception and, given that members desired to reach a balance between user needs and preparer burden, they tentatively identified additional edits. The edits are designed to ensure that preparers retain the flexibility to use estimates in disclosing the mix and amount of private partner funding. In turn, the Board agreed with staff’s proposed edits and tentatively identified additional clarifying edits to eliminate the “where available” exception consistent with its August and October 2023 Board deliberations.
Briefing Materials – Topic A
August 22, 2023
On August 22, 2023, FASAB released for public comment the exposure draft titled Omnibus Amendments: Amending Statements of Federal Financial Accounting Standards 38, 49, and Technical Bulletin 2011-1.The comment period is 30 days, ending on September 21, 2023.
The ED proposes retaining the reporting of federal oil and gas and other natural resource information as required supplementary information per SFFAS 38, Accounting for Federal Oil and Gas Resources, and Technical Bulletin (TB) 2011-1, Accounting for Federal Natural Resources Other than Oil and Gas. The ED also proposes eliminating an exception provided in SFFAS 49, Public Private Partnerships: Disclosure Requirements, to avoid reporting inconsistencies and to increase comparability.
June 13-14, 2023
At the June 2023 meeting, the Board reviewed the pre-ballot Omnibus Amendments 2023-2 exposure draft and made minor, non-technical edits to the basis for conclusions. Members generally agreed with the pre-ballot exposure draft. Mr. Dacey expressed that he would provide additional minor edits after the meeting. Once Mr. Dacey’s additional edits are reviewed and approved by other members, staff will prepare the exposure draft for final balloting.
Briefing materials – Topic E
April 18-19, 2023
At the April 2023 meeting, the Board agreed on the updates to the proposed amendments to SFFAS 38 and Technical Bulletin 2011-1. Specifically, the Board agreed on the updates related to the reliability of the estimation methodology for coal royalties from recoverable reserves to support continued Required Supplementary Information presentation. In addition, various staff presented proposed amendments to SFFAS 33, SFFAS 49, and SFFAS 3.
Staff proposed that the Board consider amending SFFAS 33, Pensions, Other Retirement Benefits, and Other Postemployment Benefits. Although members recognized that timely guidance could be provided to practitioners by clarifying certain language in the existing guidance, members were concerned about doing so in a piecemeal manner. Specifically, members noted that a more comprehensive approach through the reexamination of existing standards project would serve practitioners best, given that other aspects of SFFAS 33 could warrant additional changes. As a result, members decided not to proceed with the proposed amendment to SFFAS 33.
Staff proposed that the Board consider amending SFFAS 49, Public-Private Partnerships. Given that the Board has been addressing implementation challenges and assisting practitioners through training and outreach for over a year (and more recently with a dedicated task force), the majority of members agreed to the proposed amendment. One member objected and expressed a preference to consider all SFFAS 49 amendments in the context of the P3 project. In the end, the majority of members agreed with the task force recommendation to amend this language to help achieve the intent of SFFAS 49.
Staff proposed that the Board consider developing amendments to SFFAS 3, Accounting for Inventory and Related Property, to address seized and forfeited digital assets as part of the omnibus amendments effort. Staff presented the proposal because a federal entity had approached staff multiple times with issues analogizing and applying existing seized and forfeited property guidance from SFFAS 3 to an increasingly material amount of seized and forfeited digital assets.
While the Board agreed that digital assets are a timely and important topic, members predominantly viewed digital assets as a major substantive issue that the Board should take sufficient time to deliberate for general reporting guidance as part of a larger project. Therefore, members did not support staff’s proposal to address seized and forfeited digital assets as part of the omnibus amendments effort.
However, some members were open to considering issuing a Technical Bulletin to more narrowly address the issues identified by staff. Staff will reconvene with the working group to discuss and develop a draft Technical Bulletin for the Board’s consideration at a future Board meeting.
Briefing materials – Topic E
March 2023
The Board last reviewed the draft omnibus amendments and technical bulletin exposure drafts during the December 2022 meeting. Members supported continued RSI presentation for oil and gas information but requested additional information on the reliability of the estimation methodology for coal royalties from recoverable reserves. Staff met with the Department of Interior in March 2023 to discuss Interior’s processes and challenges for estimating coal recoverable reserves, projecting future coal production, and determining future coal prices. Staff will provide the additional analysis for members’ review prior to the April 2023 meeting.
December 13-14, 2022
SFFAS 38 – Omnibus Amendments
At the December 2022 meeting, staff presented the draft exposure drafts of the amendments to SFFAS 38, Accounting for Federal Oil and Gas Resources, and the amendments to Technical Bulletin 2011-1, Accounting for Federal Natural Resources Other Than Oil and Gas. Members discussed edits and comments on both documents during the meeting. Members agreed that additional explanation related to continued Required Supplementary Information presentation is needed in the basis for conclusions for the amendments to Technical Bulletin 2011-1.
Briefing materials – Topic F
August 23-25, 2022
During the August 2022 meeting, the members discussed the pre-research topic, review of SFFAS 38 reporting requirements. SFFAS 38, Accounting for Federal Oil and Gas Resources, requires the reporting of the value of the federal government’s estimated royalties and other revenue from the production of federal oil and gas reserves, and Technical Bulletin (TB) 2011-1, Accounting for Federal Natural Resources Other Than Oil and Gas, applies the requirements in SFFAS 38 to other federal natural resources that are under lease, contract, or other long-term agreement. When SFFAS 38 and TB 2011-1 were issued, it was the Board’s intent that the requirements would transition to basic after three years as RSI. Prior to the end of the three-year RSI period, the Board planned to decide whether the information would transition to basic as financial statement recognition or note disclosure or if the information should stay in RSI. It has been nine years since SFFAS 38 became effective, and the Board’s determination was needed to establish the reporting requirements.
It was pointed out that the language related to transition from RSI to basic is in the authoritative standards section of SFFAS 38 and not in the basis for conclusions section. As such, Board action, either by concluding that the current requirements remain as RSI or the information transition to basic, should occur.
Members agreed unanimously to leave the oil and gas information in RSI and not continue researching the topic.
Members agreed to amend SFFAS 38 through an omnibus SFFAS to conclude the open-ended proposal in the next fiscal year. TB 2011-1, which extended SFFAS 38 requirements to non-renewable natural resources, will also be amended accordingly.
Staff will draft the amendments to SFFAS 38 and TB 2011-1 through an omnibus proposal and present it to the Board sometime in the next several months.
Briefing materials – Topic G