May 2, 2021

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.

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As audit season is in high gear, it’s important for auditors to step back and plan how they are going to audit a client’s books and records. What are the red flags you’re looking for when it comes time to throw open the books and look through a huge swath of journal entries to pluck out the ones that are questionable, and need to be questioned? First off, it’s important to understand how journal entries are created at the company being audited. For an auditor, that means looking at the internal control environment to understand how a journal entry is created: Who’s authorized to create one and who can create one. You have to understand the process. How does it start and how is the entry eventually recorded onto the financial reporting system? Once you know that, you can determine whether someone can come in and override the system, or if someone can pretend to be someone else and start recording journal entries onto the system. That will help you figure out what to look for to decide what entries to pull out and ask management to get back up information to support and validate those entries. Finding the needle The key here is not to just go through the mechanics, but to really go through the exercise so you can determine if management is playing games in the recording of those transactions. You have to be able to get comfortable with that, and that means you need to be able to document what you’re looking for. Because what the auditor is really doing is looking for a “needle in the haystack”, to identify the transactions that don’t look right, that don’t make sense in the ordinary course of business. For example, if the business is not open on weekends, are transactions being posted on a Saturday or Sunday, or even on holidays? If you see rounded numbers or accounts that are seldom used, those can be red flags as well. Sometimes it can be as simple as asking managers and others like accounting, data entry and IT personnel if they’ve observed any unusual accounting entries. Depending on the size of the company and scope of the work, you might need to use computerized audit software program — some of them with AI built in — that can scan the entries to identify anomalies. Red flags When an auditor is looking for evidence of management override of controls, they can look for some of these 12 red flags indicators: ● Top-side entries ● Entries made to unrelated, unusual or seldom-used accounts ● Entries made by individuals who typically don't make entries. ● Entries recorded at the end of the period ● Post-closing entries with no explanations ● Entries made before or during the preparation of financial statements with no account numbers ● Entries that contain rounded numbers or a consistent ending number ● Entries processed outside the normal course of business ● Accounts that contain transactions that are complex or unusual in nature ● Accounts that contain significant estimates and period-end adjustments ● Accounts that have been prone to errors in the past ● Accounts that contain intercompany transactions When testing non-standard journal entries and other adjustments, you should look for documentary evidence indicating that they were properly supported and approved by management. Finally, remember that while most fraudulent entries are made at the end of a reporting period, you shouldn't ignore the rest of the year  Collemi Consulting leverages nearly three decades of experience to provide trusted technical accounting and auditing expertise when you need it the most. We regularly work with CPA firm leadership to help them reduce risk and maximize efficiencies. To schedule an appointment, contact us at (732) 792-6101.
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