The AICPA Technical Issues Committee (TIC) submitted a letter to FASB on Monday expressing concerns over the board’s reproposal seeking to simplify the classification of debt in a classified balance sheet.
FASB sought comment on the potential changes in Proposed Accounting Standards Update, Debt (Topic 470): Simplifying the Classification of Debt in a Classified Balance Sheet (Current versus Noncurrent).
The reproposal, issued Sept. 12, is an attempt to address complexities in determining whether debt should be classified as current or noncurrent in a classified balance sheet. The board’s first proposal on the topic, issued in January 2017, offered provisions to replace the current, fact-specific guidance with an overarching principle for determining whether debt should be classified as a current or noncurrent liability as of the balance sheet date.
After discussing comments from stakeholders, including the Private Company Council, FASB issued the reproposal with added provisions related to long-term financing arrangements, such as a line of credit and grace periods.
The reproposal has sparked concern among some in the health care industry who fear it could render obsolete a valuable financing option for health care entities known as variable-rate debt obligations (VRDOs).
TIC’s letter stated that reporting VRDOs solely on the demand repayment terms, as the proposal suggests, is misleading to financial statement users and does not represent the economics of the debt instrument.
“TIC believes this ED may cause health care entities to make business decisions to discontinue the use of a well-proven and cost-effective method of long-term financing,” the letter stated.
Instead, TIC supported an exception to the proposal for VRDOs to allow classification based on contractual linkage.
TIC also suggested that FASB consider:
- Adding guidance with respect to annual covenants and revising the language in FASB ASC Paragraph 470-10-45-25b to be more consistent with how the marketplace issues debt waivers. As written, TIC said, the language in the proposed waiver rules requires waivers to be for a period greater than one year, rather than just one year from the balance sheet date. For a calendar-year-end entity, this is the difference between receiving a waiver up to the next Dec. 31 versus a waiver until at least the subsequent Jan. 1. TIC members have noted a reluctance by lenders to issue waivers for a year and a day for covenants that are only measured annually.
- Removing the proposed requirement to assess the probability that any other covenants in the debt arrangement, including subjective acceleration clauses, will be violated for 12 months from the balance sheet date when a violation of a covenant at the balance sheet date has been waived. TIC said this requirement will add cost and complexity to determining the balance sheet presentation of debt.
- Providing additional adoption time for private companies if the guidance on refinancings remains in the final standard. TIC asked FASB to provide two years of additional time for private companies to comply with the standard beyond the effective date for public companies.
The comment period on FASB’s proposal ended Monday.
— Ken Tysiac (Kenneth.Tysiac@aicpa-cima.com) is the JofA’s editorial director.
