PwC supports the FASB’s proposed comprehensive framework for classifying financial instruments, which is not dependent on legal form. We agree that the primary drivers for how financial assets are classified and measured should be a company's business model for managing its financial assets, as well as the cash flow characteristics of the instruments. The accounting model should faithfully portray the economic consequences of transactions in the context of a company's business strategies and the nature of those financial instruments.
PwC agrees with the proposed change to limit the disclosures to derivatives, repurchase agreements and reverse repurchase agreements, and securities borrowing and securities lending transactions that are either offset or subject to a master netting arrangement or similar agreement.
PwC encourages the Board to continue its outreach to investors and other stakeholders as it decides which alternatives to proceed with and develops them into a proposal. PwC generally supports the Board's effort to improve the relevance and comparability of financial reporting by developing a framework for setting disclosure requirements.
PwC generally believes that the draft framework identifies the appropriate matters to consider when determining whether a modification is appropriate. It identifies the significant differentiating factors that could support financial reporting differences between public and private companies.
PwC supports the proposal to provide information about the impact of reclassifications from accumulated other comprehensive income to net income in a single footnote. Most of the information to be disclosed is already included elsewhere in the financial statements. Consolidating it and providing a roadmap to the related disclosures will provide users with improved information without the operational challenges and costs that would have resulted from requiring separate presentation on the face of the income statement of the effects of the reclassifications on individual line items, particularly when such information is not readily available.
PwC suggests enhancements to the proposed guidance in the event that others believe it will be helpful to preparers and financial statement users and will improve consistency as to when and how to prepare financial statements using the liquidation basis of accounting.
PwC agrees that improved disclosures about liquidity and interest rate risks could provide a deeper understanding of an entity's risk profile. While the Firm encourages the Board to continue its outreach to analysts and preparers as it further develops the proposed disclosures, it offers a number of recommendations for the Board's consideration.
PwC generally supports the use of a qualitative assessment that could result in an entity not having to measure the fair value of an indefinite-lived intangible asset in certain circumstances, such as when the asset's recently calculated fair value substantially exceeded its carrying amount and no significant adverse changes have since occurred.
PwC agrees with the boards' objectives and supports a single revenue recognition model that provides clearer and more consistent guidance. PwC supports the overall project. There are, however, areas where the concepts could be more clearly articulated, might be challenging to apply, or do not appear cost-beneficial. In the letter, these areas are explained in the firm's responses to the boards' questions, including responses to the FASB's questions on the US GAAP consequential amendments.
PwC does not believe that measuring all real estate investments at fair value will necessarily yield better reporting for all types of investors. However, we do believe that fair value for entities that are fundamentally investing entities, as opposed to operating entities, would provide more relevant information to users of financial statements. Further, even among investing entities that account for their real estate investments at fair value, significant diversity in application exists with respect to presentation, measurement, consolidation and disclosure.
PwC is concerned about the significant differences between the Boards' respective proposals. For example, the Boards' differ in their proposed treatment of a controlling financial interest in an investment company held by a non-investment company parent. PwC believes that such significant differences should be eliminated in order to achieve a truly converged standard.
PwC supports the FASB and IASB's efforts to develop an approach for assessing whether a decision maker is using its decision-making authority in a principal or an agent capacity. However, consolidation is only one of two important elements needed to achieve convergence in the recognition of financial assets and liabilities by financial entities. PwC's preference is for the Boards to work together to reach a converged solution for all aspects of recognition, including considering their respective guidance for derecognition of financial instruments.
PwC strongly supports FAF's plan to create the Private Company Standards Improvement Council and to maintain FASB as the sole authoritative standard-setting board for public and private companies. The Foundation's plan is the appropriate response to the private company financial reporting community's concerns about the relevance, growing complexity, and costs of compliance associated with U.S. GAAP.
PwC supports the Board's efforts to clarify the Codification, correct unintended application of guidance, and conform the use of the term fair value throughout the Codification. PwC generally agrees with the proposed changes and believes they meet the project's objective to improve the Codification. PwC provides some observations on several amendments that it believes require further consideration or clarification.
PwC supports the FASB's decision to indefinitely defer the requirement in ASU 2011-05 to measure and present reclassifications from accumulated other comprehensive income to net income by income statement line item in net income and also in other comprehensive income.
PwC expresses its support, in principle, of the use of some form of a qualitative assessment that could result in an entity not having to measure fair value of a reporting unit in certain circumstances. PwC believes the proposed update will be more cost effective than current guidance when a reporting unit's fair value substantially exceeded its carrying amount in a prior period and no significant adverse changes have since occurred. PwC believes, however, that in other situations, the proposed update may limit potential cost savings and create implementation challenges. Consequently, the Firm believes a modification to the existing guidance that expands the ability to carry forward the fair value determination of a reporting unit could...
In view of the difficulties that practice has experienced in applying hedge accounting, PwC supports the FASB and IASB's overall efforts to simplify accounting for hedging activities and to improve transparency for users of financial statements. The firm is supportive of many of the proposed amendments to hedge accounting in the FASB's proposed ASU, Accounting for Financial Instruments and Revisions to the Accounting for Derivative Instruments and Hedging Activities, issued in May 2010. PwC expects that several of the FASB's proposed amendments will help reduce the complexity of qualifying for hedge accounting and improve the consistency and comparability of financial reporting.
Consistent with the Firm's comment letters on the original IASB exposure draft and the FASB proposed ASU, PwC supports an expected loss approach to accounting for the impairment of financial assets carried at amortized cost. PwC believes the impairment model should: (i) measure credit losses consistent with current market expectations regarding collectability, and (ii) recognize the expected losses over the life of the instrument in a manner consistent with its pricing. The Firm believes this better reflects the economics of lending transactions than recognizing lifetime expected losses immediately. While preferring the conceptual merits of such a model, PwC acknowledges the operational and pragmatic concerns that exist and are...
PwC believes a single effective date approach should be adopted with an unrestricted early adoption option of any or all of the standards available to all companies. This is especially important for first-time adopters of IFRS. Based on the firm's discussions with clients that are most affected and assuming final standards on the priority projects are issued by June 2011, PwC believes the effective date should be no earlier than periods beginning 1 January 2015. This date would allow companies sufficient lead time to implement the new standards correctly the first time, reduce costs, improve operations and minimize risk.
PwC supports the Board's proposal to modify the criteria for when repurchase agreements, including reverse repurchase agreements (collectively referred as "repurchase agreements) and other agreements that both entitle and obligate a transferor to repurchase or redeem financial assets before their maturity, would be accounted for as a sale (or secured borrowing) upon transfer of such assets. In the letter, the firm provides responses to the Board's specific questions.
PwC supports the FASB's proposal to delay the effective date of the additional disclosures about troubled debt restructurings in ASU 2010-20 until it completes deliberations in its separate project to clarify what constitutes a troubled debt restructuring. The firm believes that disclosures about restructurings designed to mitigate or avoid credit losses are important to users of the financial statements. PwC, however, shares the concerns raised by the Board's constituents that implementing the new troubled debt restructuring (TDR) disclosure requirements in ASU 2010-20 in one reporting period, shortly followed by the adoption of a change in the guidance on what constitutes a TDR, would unnecessarily burden preparers and could confuse...
PwC recommends that the troubled debt restructuring recognition and measurement model also be considered in the Board's deliberations on the financial instruments project. The firm believes it is important to consider the financial instruments accounting model, including the recognition and measurement for troubled debt restructurings, holistically in order to achieve a consistent framework. PwC also recommends that the Board modify the troubled debt restructuring measurement guidance such that the relevant impairment model is independent from the identification of a troubled debt restructuring.
PwC expressed support for the boards' objective to report relevant and representationally faithful information to users of financial statements about the amounts, timing and uncertainty of cash flows arising from leases. The firm acknowledges that the proposals address the primary concern - that is, the recognition of assets and liabilities arising out of lease contracts - however, application of the proposals might reduce the income statement usefulness to many users. The firm believes that the proposals will result in significant cost and complexity for some preparers. The firm does not believe that the current proposals fully meet the objective in a number of key areas including the measurement of more complex leases, specifically...
PwC believes the FASB should continue to work with the IASB in evaluating and making changes responsive to comments received, resolving current differences between the Boards, and developing a global insurance standard. PwC expresses concerns about certain aspects of both the IASB and FASB proposals. One key concern is how the proposals would interact with other standards that are relevant to insurers' financial statements. PwC believes the FASB and IASB need to resolve their remaining differences on this project, address the concerns regarding the proposed models raised in PwC's letter to the IASB, and finalize one converged financial instruments standard, in order for a proposed insurance contracts accounting standard to be...
PwC believes the proposed ASU would improve the transparency of disclosure and provide incremental information useful to assess the risks of an employer's participation in a multiemployer plan. PwC believes, however, that there are practical implementation issues that employers and plans will face in complying with the proposed requirements, which the firm recommends that the Board consider.
PwC continues to believe that the consolidation guidance should not be reconsidered separately from a reconsideration of the derecognition guidance. PwC believes that even if the FASB adopts a consolidation model that is more consistent with the model described in the Staff Draft, convergence, and therefore consistency and comparability, will not be achieved, particularly for securitization entities, unless a converged derecognition model is also adopted. Accordingly, PwC believes that the FASB should reconsider the consolidation guidance together with the derecognition guidance.
PwC agrees with the theoretical merit of many of the concepts included in the proposed standard. PwC believes, however, that there are a number of situations where the concepts may be difficult to apply, do not appear cost beneficial, or both. PwC also agrees with the boards that full retrospective application of the proposed standard might benefit users, but a more pragmatic approach to transition might likely be needed in many situations. The firm encourages the boards to allow for early adoption of the proposed standard.
PwC recommends that the FASB and IASB develop a set of consistent principles to govern the use of other comprehensive income. PwC encourages the Boards to add to their post-2011 agendas a project to address the reporting of financial performance, the purpose and use of other comprehensive income, and the extent to which recycling is appropriate. Many companies and financial statement users continue to believe that a measure of net income is important. PwC, therefore, supports the requirement to present this sub-total within a single statement of comprehensive income and the Firm believes strongly that this line item should be retained as the Boards develop their thinking on the presentation of financial statements.
Although PwC generally agrees with proposals that would enhance consistency between U.S. GAAP and IFRS, the Firm believes the ED should be modified in certain areas described in detail in the letter and recommends that the FASB and the International Accounting Standards Board (IASB) work together to reconcile any substantive differences and work to achieve convergence in fair value measurement and disclosure guidance.
As the financial instruments area is fundamental to any convergence efforts, and the cost to the capital markets of divergence would be significant on many levels, PwC urges the FASB and IASB to work collaboratively during the redeliberations phase to resolve remaining substantive differences. PwC supports the FASB's objective of developing a model that increases the decision-usefulness of the information reported about financial instruments. However, PwC believes that the Proposal, taken as a whole, does not contain the most appropriate solutions to achieve that objective.