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Beyond the Debits and Credits: A Management and Governance Checklist for Implementing FASB ASU 2016-14

Beyond the Debits and Credits: A Management and Governance Checklist for Implementing FASB ASU 2016-14

 The time has come to dive into the details of how to implement FASB Accounting Standards Update (ASU) 2016-14, Presentation of Financial Statements of Not-for-Profit Entities. For that purpose, you can’t beat a good checklist. While there are several checklists available online to assist you with the financial-statement-presentation aspects of ASU 2016-14 implementation, this checklist addresses the governance side of implementation. What needs to be considered from a process perspective; what needs to be communicated and to whom?

The checklist is divided into the five key areas:

  • Classifying net assets
  • Reporting investment returns
  • Reporting expenses by function and nature
  • Preparing the statement of cash flows
  • Preparing disclosures about liquidity and availability of financial assets

Each section contains a high-level overview of the requirements, followed by questions that management should consider when implementing the standard as well as steps that may be taken to ensure that your board understands the implications.

Net Asset Classification

ASU 2016-14 replaces the three classes of net assets – permanently restricted, temporarily restricted and unrestricted –with two classes – net assets with donor-imposed restrictions and net assets without donor restrictions. To ensure that there is no loss of information, the standard requires not-for-profits to provide information about the nature and amounts of donor restrictions on net assets, as well as the amounts and purposes of net assets that have been designated by the governing board.

Amounts by which endowment funds are underwater will now be reported within net assets with donor restrictions rather than in unrestricted net assets. In addition, organizations will be required to disclose their policy for spending from underwater endowments and the aggregate original gift amounts of underwater funds, along with the fair value of those funds.

The policy option to imply a time restriction that expires over the useful life of donated long- lived assets will no longer be available. Instead, absent specific donor stipulations, restrictions on capital assets will be released when the asset is placed in service.

 

Considerations Yes/No Actions Required
1. Should current classifications be reviewed to ensure accuracy?    
a) Are processes in place to ensure that donor restrictions have been released appropriately?    
b) Are there unidentified balances in temporarily restricted net assets that should be examined?    
2. Does the organization have board designated net assets?    
a) Are the purposes for which the net assets are designated still appropriate?    
b) Has the board’s approval of designated amounts been adequately documented?    
3. Does the organization have endowment funds that are underwater?    
a) Are systems and processes in place that enable identification of underwater funds?    
b) Will the transfer to net assets with donor restrictions adversely affect ratios or covenants?    
c) Is the organization’s policy for spending from underwater endowments still appropriate and adequately documented?    
4. Does the organization have a policy to imply a time restriction that expires over the useful life of donated long-lived assets?    
a) What is the potential effect of releasing from restriction net assets to which that policy has been applied?    
5. Does the organization’s chart of accounts need revisions to support the net asset changes?    
Considerations for Board Communication
1. Explain the new net asset categories.    
a) Review terminology changes.    
b) Illustrate how the changes will affect statement presentation.    
2. Describe any impact of underwater endowments on net asset balances.    
3. Describe any impact on net asset balances if policy to imply a time restriction on donated long-lived assets is currently being used.    
4. Reaffirm prior board decisions.    
a) Review existing board designations.    

 

b) Ensure policy for spending from underwater endowments is still appropriate.    
5. Discuss additional costs associated with changes.    
a) Additional audit fees    
b) Necessary system and/or process changes    

Reporting Investment Returns

Under ASU 2016-14, investment returns will be presented net of external and direct internal expenses in the statement of activities. The current requirement to disclose the amount of netted investment expenses has been eliminated. In addition, NFPs will no longer be required to display the investment return components (income earned and net realized and unrealized gains or losses) in the rollforward of endowment net assets.

 

Considerations Yes/No Actions Required
1. Identify the costs, if any, that are being netted today.    
a) Do costs currently being netted meet the definition in the standard?    
b) Will any additional costs need to be netted?    
2. Consider how to communicate any significant changes in net investment revenue reported in the financial statements.    
a) Who needs to communicated with?    
b) What is the best means of communicating (i.e., in person, by email, other)?    
3. Will a change in net investment return have any adverse consequences that should be addressed prior to implementation?    
a) Debt covenants    
b) Regulatory requirements    
c) Other    
4. Does the organization produce other reports that should be revised to provide consistent information?    
Considerations for Board Communication
1. Explain the new requirement for netting investment expenses.    
2. Identify any changes to the current amounts, if any, being netted.    
3. Describe any impact on net investment return to be reported in the financial statements and any adverse consequences of the change.    

Reporting Expenses by Function and Nature

ASU 2016-14 requires an analysis of total expenses by both their function and nature in a single location either on the face of the statement of activities, as a schedule in the notes to financial statements, or in a separate financial statement. To the extent that expenses are reported by other than their natural classification (such as salaries included in cost of goods sold or facility rental costs of special events reported as direct benefits to donors), they must be reported by their natural classification in the functional expense analysis. For example, salaries, wages, and fringe benefits that are included as part of the cost of goods sold on the statement of activities should be included with other salaries, wages, and fringe benefits in the expense analysis. External and direct internal investment expenses that have been netted against investment return may not be included in the functional expense analysis. Enhanced disclosures about how costs are allocated among functions are also required.

 

Considerations Yes/No Actions Required
1. Determine the best format for presenting the expense analysis:    
a) On the face of the statement of activities?    
b) In the notes to the financial statements?    
c) As a separate statement (i.e., a statement of functional expenses)?    
2. Are the current functional expense classifications still appropriate?    
a) Are there too many?    
b) Are there too few?    
c) Is any renaming necessary to accurately depict what is included in a specific function?    
3. Ensure functional classifications are being accurately captured in the financial statements.    
a) What processes are in place to ensure that expenses are properly classified?    
b) Is a review of the classification necessary to ensure accuracy?    
4. Are expenses by natural classification being properly captured?    
a) What processes are in place to ensure expenses are properly recorded?    
b) Are employee reimbursements in accordance with the organization’s policy?    
5. Are the current natural expense classifications still appropriate?    
a) Are there too many?    
b) Are there too few?    

 

6. Are current allocation methodologies appropriate?    
7. If comparative years are presented, should the expense analysis be presented for the current year only or for all years presented? (Note: NFPs that previously were required to present a statement of functional expenses do not have the option to omit prior-period information.)    
Considerations for Board Communication
1. Discuss how this analysis may differ from the similar analysis required on the IRS Form 990.    
2. Identify any additional costs anticipated in preparing the disclosure (i.e., costs to review existing functional expenses).    

Statement of Cash Flows

ASU 2016-14 allows an organization to present cash flows from operating activities using either the direct or indirect method. If the direct method is chosen, the indirect reconciliation is not required, but may still be provided if desired.

Considerations Yes/No Actions Required
1. Determine which presentation method is best for the organization.    
2. If contemplating a change:    
a) Consider recasting current statement into the new format.    
b) Identify any system changes needed to support the new format.    
c) Determine if any process changes will be necessary.    
d) Decide whether to include the indirect reconciliation in the financial statements.    
Considerations for Board Communication
1. Discuss the pros and cons of each format and get input on the board’s preference.    
2. Consider preparing statements in each format and highlight differences.    
3. Identify any additional costs associated with making a change.    

Disclosures about Liquidity and Availability of Financial Assets

The new standard requires not-for-profits to disclose both qualitative and quantitative information about liquidity and availability of resources as follows:

  • Qualitative information that communicates how the organization manages its liquid resources available to meet cash needs for general expenditures within one year of the balance sheet
  • Quantitative information that communicates the availability of the organization’s financial assets at the balance sheet date to meet cash needs for general expenditures within one year of the balance sheet The availability of a financial asset may be affected by its nature; external limits imposed by donors, laws, and contracts with others; and internal limits imposed by governing boards.

These disclosures can take many forms depending on the relative liquidity of an organization’s resources, donor-imposed restrictions on those resources, internal board designation of resources, and so on.

Considerations Yes/No Actions Required
1. What is the message the organization wants to convey?    
a) Does the organization have ample resources to fund activities over the next 12 months?    
b) Are there significant restrictions or internal designations limiting the use of resources?    
c) What additional sources of liquidity are available?    
2. Identify the best way to present the message:    
a) Text only?    
b) Tables and text?    
3. Identify current procedures around board designations.    
a) Are procedures formally documented?    
b) Does the board delegate authority for designation of net assets?    
i.   Is the delegation documented?    
ii. Are the levels of delegation still appropriate?    
4. Review current policies.    
a) Will any new policies be required?    
i.   Net asset designation policy?    
ii. Operating reserve policy?    
b) Do existing policies need updating or formalizing?    
5. Are system changes needed to easily capture information for disclosure?    
6. Does the organization’s chart of accounts need revisions to support the disclosure?    

 

7. Do current processes need to be modified?    
8. Are any new processes necessary?    
9. If comparative years are presented, should the liquidity disclosures be presented for the current year only or for all years presented?    
Considerations for Board Communication
1. Explain the disclosure requirements.    
2. Discuss the best presentation for achieving desired transparency.    
3. Recommend any policy changes or additions.    
4. Discuss any additional costs anticipated for preparing the disclosures.    

Source: “Beyond the Debits and Credits: A Management and Governance Checklist for Implementing FASB ASU 2016-14,” American Institute of Certified Public Accountants, Not-for-Profit Section.