Help your clients prepare now for the adoption of the new leasing standard
Effective for fiscal years beginning after December 15, 2021 and — interim periods within fiscal years beginning after December 15, 2022
— the Financial Accounting Standards Board (FASB)’s Accounting Standards Update (ASU) 2016-02 (ASC Topic 842) will introduce a significant change to lease accounting for most private companies. The new standard will, for the first time, generally require companies to bring their long-term lease obligations onto the balance sheet. For the past five years, Collemi Consulting has been working with CPA firm leadership and their respective clients — particularly ones who are lessees in the transaction — to understand and implement it.
Who will be affected?
ASC Topic 842 will mean that approximately $3 trillion of right-of-use (RoU) assets and lease payment liabilities will be added on to U.S. companies’ balance sheets. Certain industries, such as retail, telecommunications and real estate, will be severely impacted — but all businesses that participate in leasing transactions will be impacted to some degree.
You may think it’s not a lease, but certain terms and conditions will make it one!
Fact Pattern: consider a consumer products company (CPC) that has a two-year agreement with a contract manufacturer for a dedicated production line to manufacture a line of store-brand household products. The contract states that the CPC has exclusive use of the production line; that the manufacturer must perform maintenance on the product line; and that the CPC will issue orders to the manufacturer about the quantity and timing of product deliveries.
According to ASC Topic 842, this contract contains a lease because the CPC (or the lessee) has the right to use the dedicated production line for two years, and the dedicated production line is an implicitly identified asset because the manufacturer has only one line that can fulfill the contract and does not have the right to substitute the specified production line. The CPC must now recognize both a RoU asset and an associated lease liability on the balance sheet!
Some fine print
An audit engagement team will need to discuss with management the accounting requirements of the new guidance to assess whether the client is adequately planning for the transition, including the use of the practical expedients and accounting policy elections that are available. The audit team may want to discuss the associated business and tax implications early on, to ensure that all issues are addressed in a timely manner.
The audit engagement team will also need to engage with management about the implications of the available elections. For example, electing to avoid separating lease and non-lease components; or weighing whether the election of a risk-free rate as the discount rate will make the transition easier and take less time, but will result in larger asset and liability balances.
