In its December 4 response letter, PwC supported the FASB’s recent proposal to issue to a new Codification section: ASC 812, Consolidation. ASC 812 is not new guidance. It consist of the current consolidation guidance reorganized in a manner intended to facilitate a user’s application of the consolidation rules. The proposal is not intended to change consolidation outcomes or how the guidance currently in ASC 810 has been historically applied.
As proposed, ASC 812 will consist of three subtopics, consisting of an overview, guidance applicable to variable interest entities, and guidance applicable to voting interest entities. The latter two subtopics are intended to be largely standalone; for example, if an entity is deemed to be a variable interest entity, all guidance relevant to it (primary beneficiary evaluation, measurement upon initial consolidation, etc.) will appear in the VIE Subtopic.
The proposal also contains clarifications to certain key consolidation terms.
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