Recommendations on Hedge Accounting and Accounting for Transfers of Financial Instruments: AAA Financial Accounting Standards Committee. (Commentary)

Vincent, Linda INTRODUCTION This article summarizes some of the comments of the Financial Accounting Standards Committee of the American Accounting Association (hereafter the Committee) on the Joint Working Group of Standard Setters (JWG 2000) "Recommendations on Accounting for Financial Instruments and Similar Items" (hereafter the Proposal). These comments reflect the views of the individuals on the Committee and not those of the American Accounting Association. Although the JWG provides comprehensive guidance regarding accounting for financial instruments in the Proposal, in this commentary we discuss only three aspects of that guidance: (1) the elimination of hedge accounting, (2) the treatment of securities repurchase agreements as sales of assets coupled with executory contracts to repurchase those assets rather than as secured borrowings, and (3) the recognition of the maximum amount rather than fair value of guarantees in transfers of financial instruments. The Proposal differs substantially from the FASB's (1999) "Preliminary Views on Major Issues Related to Reporting Financial Instruments and Certain Related Assets and Liabilities at Fair Value" (hereafter the Preliminary Views) and/or current practice regarding these transactions, and we believe it does not reflect their economic substance. The Committee supports the other significant aspects of the Proposal. (1) HEDGE ACCOUNTING The JWG proposes eliminating "special accounting for financial instruments that are entered into as part of risk management activities" (para. 153), which we refer to as "hedge accounting. " Under the Proposal, derivatives and all other financial instruments that are not explicitly excluded from the Proposal are reported at fair value on the balance sheet and changes in their fair values are reported in operating income. (2) The Proposal does not change the accounting for items being hedged, so hedging relationships will be properly reflected in earnings only if the hedged item happens to be fair-valued on both the balance sheet and income statement. The JWG's position on hedge accounting contradicts existing U.S. GAAP that permits hedge accounting for derivatives that qualify as part of an effective hedging relationship (SFAS No. 133, FASB 1998). Two forms of hedge accounting permitted in SFAS No. 133 allow firms to match the timing of the recognition of gains or losses associated with derivative instruments to that of the earnings associated with the hedged item. For fair value hedges, the gain or loss on the derivative instrument and the change in fair value of the hedged item are recognized in operating earnings as they occur. For cash flow hedges, the gain or loss associated with the effective (ineffective) portion of the derivative hedge is recognized in other comprehensive income (operating earnings) as it occurs. The gain or loss associated with the effective portion of the hedge is subsequently amortized into operating earnings to match the earnings effect of the hedged item. Although the Proposal differs substantially from current U.S. GAAP, it does not deviate radically from the trajectory of U.S. standards. The FASB states in SFAS No. 133 (para. 216) that the standard "is an additional step in the Board's project on financial instruments and is intended to address the immediate problems about the recognition and measurement of derivatives while the Board's vision of having all financial instruments measured at fair value in the statement of financial position is pursued. " Further, in a summary of differences between the Proposal and its Preliminary Views in its preface to the proposal (see page iv of the Proposal), the FASB states that both documents "would affect hedge accounting similarly. Both would preclude any form of hedge accounting that affects accounting and reporting for a financial instrument, and neither would change existing hedge accounting that does not involve the accounting and reporting for a financial instrument. …