Thursday, January 20, 2011

FASB ASU 2011-01 Defers Eff. Date of Troubled Debt Restructuring Disclosures Required in 2010-20; All Other 2010-20 Disclosures Keep Orig. Eff. Date

Earlier today, the Financial Accounting Standards Board released Accounting Standards Update No. 2011-01 (ASU 2011-01). The ASU is entitled, Receivables (Topic 310): Deferral of the Effective Date of Disclosures about Troubled Debt Restructurings in Update No. 2010-20.

ASU 2010-20, issued in July, 2010 is entitled: Receivables (Topic 310):Disclosures about the Credit Quality of Financing Receivables and the Allowance for Credit Losses.

ASUs are released to communicate changes made to accounting standards under FASB's Codification.

My two (three) cents (note: refer directly to the ASUs for the official requirements, the following is my own take on key points from the ASU; please refer to the disclaimer posted on the right side of this blog):

  1. TDR disclosures are the only 2010-20 disclosures deferred: ASU 2011-01 defers the effective date of only a portion of the new disclosures under ASU 2010-20, specifically, those pertaining to Troubled Debt Restructurings (TDRs). Other than the deferral of the TDR disclosures announced today, all other disclosures required in ASU 2010-20 relating to the credit quality of financing receivables, and the allowance for credit losses, are still required as of the original effective date of ASU 2010-20 - essentially, for calendar year companies, the original effective date of ASU 2010-20 was 2010 for public co's, and 2011 for private co's.
  2. TDR accounting/definition guidance and TDR disclosures will have coordinated effective date: The reason why FASB decided to defer the effective date for the new TDR disclosures relates mainly to the fact that FASB is separately working on guidance relating to the definition of a TDR, and in response to constitutent comments received on the earlier ASU, FASB decided to require the new disclosures of TDRs concurrent with the new definition of TDRs and related guidance. FASB states in ASU 2011-01: "Currently, that guidance is anticipated to be effective for interim and annual periods ending after June 15, 2011."
  3. Private co's already subject to deferral of all disclosures in 2010-20: The deferral in ASU 2011-01 is specified as applicable to public companies only, because ASU 2010-20 already deferred the effective date for private companies (for all of the disclosures in ASU 2010-20) until annual periods ending on or after Dec. 15, 2011. That is, only public companies were required, under ASU 2010-20, to provide all of the new disclosures set forth in ASU 2010-20 for interim and annual periods ending after Dec. 15, 2010. Therefore, the immediate need (e.g. for calendar year-end companies) for a deferral of effective date of the TDR disclosures in ASU 2010-20 pertained to public companies only.

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