A 2005 SEC survey estimated the off-balance sheet obligation associated with operating leases for public companies at $1.25 trillion. In 2016, the FASB and IASB issued new standards to bring these obligations on the balance sheet.
While the FASB and IASB standards are similar, there are differences between them. Both will mostly affect lessee accounting. The principal difference between the two standards is that the FASB standard retains a dual lease classification model that preserves the current lessee expense recognition pattern for operating (straight-line) and capital (accelerated) leases, whereas the IASB standard moves to a single model with one expense recognition pattern for lessees. (For more information on the differences, see the “Summary” section, pages 7–9 from Accounting Standards Update (ASU) 2016-02, Section A – Lease Amendments to the FASB Accounting Standards Codification.)
When do I need to be compliant with ASC 842?
The guidance in ASU 2016-02 will take effect for public companies for fiscal years, and interim periods within those fiscal years, beginning after Dec. 15, 2018. For all other organizations, it will take effect for fiscal years beginning after Dec. 15, 2019, and for interim periods within fiscal years beginning after Dec. 15, 2020. Early application is permitted for all organizations.
Should I adopt the standard early?
Early adoption is permitted for all companies. However, whether or not early adoption may be advantageous for your company depends on your particular circumstances. Once you have started the process of gathering your data on leases, you will be in a better position to weigh the pros and cons. A few factors that can influence your decision are the following:
- Your level of readiness. The new standards will have a ripple effect throughout your company, influencing systems, controls, processes, as well as the communication of all these changes throughout your company and to your downstream departments. If you have collected your lease data and are advanced in the implementation, then you might consider adopting early. Otherwise, it is better to focus on meeting the deadline.
- Your progress/approach to the revenue recognition standard Accounting Standards Codification (ASC) 606. ASC 606, the new revenue recognition guidance, will be effective in the first quarter of 2018 for calendar-year public companies and in 2019 for nonpublic entities. If you’re far along in implementing ASC 606, you might consider implementing ASC 842 early to capitalize on that momentum and keep your transition resources engaged.
- Assess whether your leases will require modifications prior to adopting the standard. It might be in your favor to wait until the implementation deadline so as to have more time to restructure certain large leases whose terms might expire before the deadline.
What periods are affected by the standard upon its adoption?
The new lease standard calls for a modified retrospective transition. 2017 and 2018 data is needed for adoption in 2019, for calendar-year-end public companies.
What happens to the straight-line provision in the income statement?
The straight-line provision relates to the current pattern of expense recognition for operating leases. This pattern will not change for operating leases under ASC 842.
Do I really have to gather all lease information, or can I estimate? Is there a materiality threshold?
Under International Financial Reporting Standard 16, low-value assets do not need to be recognized on the balance sheet. The IASB has indicated that low-value assets are those valued under $5,000 when new (as indicated by IASB). The guidance in ASU 2016-02, however, does not provide such an exemption although, as with implementation of any accounting standard, materiality should be considered.
Will I need software to track and account for leases under the new standard?
Software selection will undoubtedly become an important part of implementing the leasing standard, and should be front of mind for any company undergoing this transformation. However, companies do have a lot of flexibility in terms of timing software purchase, and there is no need to select a software solution upfront. Rather there are definite advantages (such as pricing or better alignment with your company’s needs) to waiting to select software until your company has identified and collected all its lease data. Your company can first prioritize the collection of data into a central repository, and then define the best-in-class processes and governance of updating and managing your data. Once you have this central repository, you can select the best software solution for your needs, since a central data repository should be able to interact with any software.
Going forward, will we need to change our approval process for new leases to ensure that we account for them at the appropriate time?
It is important that you catch your leases upstream by thinking proactively of any new leases you are entering into from now on. Going forward, account for leases and put them on the balance sheet as soon as you contract them. This is important because it will not only ensure your future compliance, but also speed up your company’s transition process to the new standards. The first step toward implementing these proactive measures is to educate the people at your company’s various locations by establishing a process they can use to identify new leases. The second step is to assess the level of centralization of your operations. To acquire the best efficiency and to capture your data adequately, centralization makes sense. So, if not already there, your company might need to identify the necessary future steps it needs to take in this direction.
We have lots of groups negotiating leases; how do we find them all?
When your company engages in the process of identifying all leases, this process will include identifying lease owners within the company. So, by the end of this process, you should have catalogued all groups negotiating leases. The next recommended step is to inform and train all these groups on the lease standard, and request that they verify and confirm that they forwarded all leases within their control. This will ensure that your company can make a positive, confident statement regarding the completeness of your identified leases. Finally, in addition to identifying the groups negotiating leases, your company needs to plan for centralizing the review process once these groups are located. The key to this part of the process is finding the proper time to centralize contract reviews - such as legal review or procurement signoff - and ensure that all contracts go through that checkpoint going forward.
What departments in my company will be affected? Can finance manage this transition alone? Who should be part of the team for this initiative?
Several departments in your company will be affected by the changes in lease accounting, including the finance department, but not exclusively. For example, with the addition of leases to the balance sheet, organizations should review existing contractual agreements, such as lending covenants, to seamlessly adjust to the new standard. Accordingly, it may be wise to include treasury, legal departments and others as part of a transition team.
For example, your company will have to take into account the impact on the following:
- Treasury. The new standards will trigger the loss of the off-balance sheet benefit for financing operating leases, so your company might need to reconsider debt covenant compliance.
- IT/Operations. Your company will probably needs new processes, systems and controls to gather lease data and account for current leases, as well as for future ones.
- Tax. Your review of leases may uncover the need to book tax differences and taxes that have no basis in either the right of use asset or in the lease obligation, resulting in deferred assets/liabilities associated with every lease. In addition, there will be significant uncertainty regarding the way states will treat new assets for income, sales and property tax issues.
- Regulatory compliance. Since leases will be recorded as new assets and liabilities on the balance sheet, this will have an impact on regulated companies, such as banks and others. To ensure compliance, these companies can anticipate additional scrutiny from regulators and should start preparing for the standard now, as well as start planning for more regulatory capital.
How do I know if I have an embedded lease?
Your company will have to identify and record all leases on the balance sheet, so this means that you may need to reconsider your contracts not labeled as lease agreements (e.g., service agreements) to identify any embedded leases you might not previously have accounted for separately. For example, if you have agreements with third-party contractors, do these include the exclusive use of an identified asset? If the answer is yes, then the contract might contain an embedded lease.
Can my shared service center(s) handle this?
Global organizations need to account for their international leases as well. They will encounter foreign language issues, as well as challenges relating to the identification and collection of leases. A great option would be for the shared service centers around the globe to handle this process for these companies in the same way that they can handle their fixed asset process. This is possible if your company is proactive and gets ready to tackle these challenges early. The lease volume that you have and your capacity for translating your leases will determine whether you can handle this situation in-house, in your service center(s), or whether you need to seek additional help. The best course of action is to map the implementation of the lease accounting process to your financial hubs around the globe and to streamline the process for efficiency.
Daryl Buck is a National Managing Partner, Advisory Services, Joseph Brown
is a National Managing Partner, Strategic Federal Tax Services, and Chris Stephenson is Principal, Financial Management at Grant Thornton.