What is CECL’s impact on private nonbank companies?
This article provides an overview of how CECL might impact your nonpublic (private company) financial reporting including your numbers and disclosures.
An Overview of CECL
The Current Expected Credit Losses (CECL) model was introduced by the Financial Accounting Standards Board (FASB) through Accounting Standards Update (ASU) No. 2016-13, "Financial Instruments—Credit Losses (Topic 326): Measurement of Credit Losses on Financial Instruments."
ASU 2016-13 was issued in June 2016 and it replaced the previous incurred loss impairment methodology with the CECL methodology. The new model requires more timely recognition of credit losses associated with financial instruments.
Effect on Nonbank Entities
Most nonbank entities have financial instruments or other assets (such as trade receivables, lease receivables, and held-to-maturity debt securities) that are subject to the CECL model.
Because financial assets of nonbanks tend to be held for a shorter duration than those of banks, nonbanks will generally be less affected by the new CECL standard.
According to Deloitte, many nonbank entities have disclosed that the impact of the new CECL standard is immaterial to their financial statements or did not disclose the adoption of the new CECL standard at all.
Nonpublic companies may use simpler methods for estimating expected credit losses and making forecasts about the future (as compared to public companies), as long as those methods are reasonable and supportable. They may also have more flexibility in the types of information they consider and the ways they document their estimates.
However, they will still need to comply with the basic principles of the CECL model, including the requirement to estimate expected credit losses over the life of the financial instruments.
Changes in Disclosures
The CECL standard introduces principles-based disclosure requirements, giving entities flexibility to determine the nature and extent of the information to be disclosed.
Entities are required to provide sufficient information to enable users of their financial statements to understand the credit risk inherent in a portfolio, management's estimate of expected credit losses, and changes in the estimate of expected credit losses that have taken place during the period.
Changes in Allowance for Uncollectibles
Under the CECL model, an entity recognizes its estimate of expected credit losses as an allowance, which incorporates forward-looking information and eliminates barriers to the timely recognition of losses under legacy incurred loss models. This is a significant shift from the previous incurred loss model, which only recognized losses when they were incurred.
Effective Dates for CECL Standard
The guidance became effective on January 1, 2023, for private companies. Public business entities that meet the SEC’s definition of smaller reporting companies and have a calendar year-end have the same effective date, January 1, 2023.
Can one person post a journal entry without a second-person approval? If yes, who?
How often are journal entries posted, and for what purpose?
Have there been any unusual journal entries during the year?
Are estimates adjusted or recorded with journal entries? If yes, who makes those entries, and how often?
Does the company have a separate journal entry software package (such as Blackline) that interfaces with the general ledger?
What journal entries are made in creating the financial statements, including those after the trial balance is taken from the accounting package (for example, the company downloads the trial balance to Excel)?
Are all journal entries in the financial statement creation phase reviewed and approved by a second person? If yes, by whom?
Has management asked anyone to override journal entry controls or protocols?
Inspect sample documents and journal entries. Also, observe who is doing what. Then document your inquiries, the records inspected, and your observations as a part of your walkthrough process. Also, document who you talked with and on what date.
Scan a Month's Journal Entries
Consider downloading all journal entries for a particular month and scanning those. Doing so will enable you to see the typical entries made. Most accounting systems differentiate journal entries from other transactions, so it's usually easy to segregate all journal entries for review.
Scanning a month's journal entries is not a required procedure, but one that I suggest.
So, as you scan the journal entries, what are you looking for? What types of entries might imply that fraud is present?
Indicators of Fraud Risk
The following are potential indicators of fraud risk:
Nonstandard journal entries made at year-end, especially those for round numbers
Entries made to seldom-used accounts
Post-closing entries with no explanation
Entries made by persons that seldom do so
Entries made to force accounts to balance without performing proper reconciling procedures
Plan Your Journal Entry Responses
Plan to test journal entries based on your risk assessment procedures. If you notice particular risks, then audit those areas.
Here are examples of risks and responses:
Test more entries if one person records journal entries without a second-person approval. Why? There's more risk.
If you note unusual logical access rights, consider downloading all journal entries and sorting them by persons to see if there are any unusual journal entries.
If significant revenue entries are made in the last month, test those.
If one person consolidates the financial statements in Excel, making adjustments without a second-person review, test that process.
Journal entries may be appropriate throughout the year because they are subject to good controls. Even so, someone might inflate the numbers in the financial statement creation process (after exporting the original numbers to a spreadsheet, for example).
It is wise to test journal entries made late in the year. As management approaches year-end, they might realize the company needs to meet specific targets (e.g., a certain level of net income) for them to earn bonuses. If true, management has a potential motivation to manipulate the numbers, especially at year-end.
We'll look at the objectives of SAS 143, auditor responsibilities (including risk assessment and responses), the nature of estimates, documentation requirements, and overall evaluation of your work to ensure appropriateness and completeness.
To get us started, here are a few examples of estimates:
So, what is an accounting estimate? It's a monetary amount for which the measurement is subject to estimation uncertainty. Of course, you need to consider the financial reporting framework as you think about the estimate. For example, an estimate might be significantly different when using GAAP versus a regulatory basis.
But what is estimation uncertainty? It's the susceptibility of an estimate to an inherent lack of precision in measurement. In layperson's terms, it's an estimate that is hard to pin down.
SAS 143 Objectives
The objective of SAS 143 is to see if the accounting estimate and related disclosures are reasonable by obtaining sufficient appropriate audit evidence.
Nature of Estimates
Some estimates are simple, while others are difficult. For example, estimating the economic life of a vehicle is straightforward, but computing an allowance for uncollectible receivables might be complex.
But even one type of estimate, such as an allowance for uncollectible, can vary in complexity. For example, the allowance computation for uncollectible receivables is usually more complex for a healthcare entity (e.g., more payor types) than for a small business. Why? Because it is more complex and more challenging to determine. Therefore, the estimation uncertainty for a healthcare entity (with many payor types) is higher than that of a small business with one type of customer. Additionally, the volume of transactions could be higher for a healthcare entity versus a small business.
So, the inherent subjectivity of an estimate creates estimation uncertainty.
Consider estimation uncertainty in this manner: ask twenty people to compute the allowance for a hospital and then ask them to do the same for the small business's uncollectible estimate. How much variation would you expect? Yes, much more for the hospital because the inherent risk is higher.
SAS 143 tells us to increase our risk assessment procedures and further audit procedures as the estimation uncertainty increases. We perform more risk assessment work concerning the hospital's allowance than that of the small business. Moreover, we complete more extensive further audit procedures for the hospital's allowance than for the small business's estimate.
More risk, more work.
To understand SAS 143, we need to know the underlying concepts.
SAS 143 Concepts
You need to assess the risk of material misstatement at the relevant assertion level. Further, you are required to assess inherent risk and control risk separately. And as you assess inherent risk, you might encounter significant risks.
The Spectrum of Inherent Risk
Usually, a hospital's valuation assertion related to receivables is relevant, and the inherent risk is often high due to its subjectivity, complexity, and volume of transactions (i.e., inherent risk factors). Therefore, the valuation assertion's risk might fall toward the end of the spectrum of inherent risk. On a ten-point scale, we might assess the inherent risk as a nine or a ten. And if we do, it is a significant risk, affecting our professional skepticism.
Professional Skepticism and Estimates
Our professional skepticism increases as the estimation uncertainty rises (or at least, it should). Why? The potential for management bias may be present since it's easier to manipulate complex estimates. And complexity can be a smokescreen to hide bias, increasing the need for internal controls.
As estimates become more complex, entities increase internal controls (or at least, they should). And consequently, auditors need to evaluate the design and implementation of those controls. Additionally, auditors must determine whether they will test the controls for effectiveness.
Another SAS 143 concept is the reasonableness of the estimate.
Reasonableness of Estimates
For an estimate to be reasonable, the applicable financial reporting framework must be its basis. Additionally, management should consider the facts and circumstances of the entity and the related transactions. In creating a reasonable estimate, management will often use the following:
Let's consider these elements using the allowance for uncollectible receivables.
First, management considers the financial reporting framework. If the entity uses GAAP, it makes sense to create the estimate. No allowance is necessary if the cash basis of accounting is in use. In this example, we'll assume the company is using GAAP.
In computing an allowance for uncollectible, an entity might calculate the estimate as a total of the following:
20% of receivables outstanding for more than 60 days
60% of receivables outstanding for more than 90 days
90% of receivables outstanding for more than 120 days
And what assumptions might management consider? Bad debt percentages have stayed the same over time. The company needs to increase the percentages if collectible amounts erode.
Finally, consider the allowance data. In this example, it would typically be an aged receivable listing. Such a listing breaks receivables into aging categories (e.g., 0 to 30 days; 31 to 60 days; etc.). Such data should be consistent. Suppose the company purchases new software that computes the aged amounts differently using different data than previously. If this occurs, management and the auditors need to consider the reasonableness of the new data.
Is the Estimate Reasonable?
Most importantly, estimates need to make sense (to be reasonable) in light of the circumstances. While consistent methods, assumptions, and data are desirable, change, such as a slowdown in the economy, can require new ways of computing estimates.
One more concept is that of management's point estimate and disclosure.
Management's Point Estimate and Disclosure
The auditor will examine management's point estimate and the related disclosures to see if they are reasonable. How? Review the estimate's development (how was it computed?) and the nature, extent, and sources of estimation uncertainty.
If circumstances are similar to the prior year, then the estimate's method, assumptions, and data will typically be similar. Likewise, the disclosure will be much like the preceding period.
But if, for example, the economy slows significantly, the percentages applied to the aged receivable categories (see above) may need to increase so that the allowance for uncollectible is higher. The auditor might question the estimate if management did not raise these percentages.
The company should disclose how the estimate is created and the nature, extent, and sources of estimation uncertainty.
Now, let's see what the SAS 143 requirements are.
SAS 143 Requirements
The requirements for estimates are conceptually the same as in any area. The auditor does the following:
Perform risk assessment procedures
Identify and assess the risk of material misstatement
Develop responses to the identified risks and carry those out
1. Perform Risk Assessment Procedures for Estimates
As you consider the entity and its environment, consider the following:
Transactions and other events that give rise to the need for estimates and changes in estimates
The applicable financial reporting framework as it relates to estimates
Regulatory factors affecting estimates, if any
The nature of estimates and related disclosures
Next, as you consider internal control, ask about the following:
Nature and extent of estimate oversight (who oversees the estimate? how often is the estimate being reviewed?)
How does management identify the need for specialized skills or knowledge concerning the estimate?
How do the entity's risk assessment protocols identify and address risks related to estimates?
What are the classes of transactions, events, and conditions giving rise to estimates and related disclosures?
How does management identify the estimate's methods, assumptions, and data sources?
Regarding the degree of estimation uncertainty, how does management determine the range of potential measurement outcomes?
How does management address the estimation uncertainty, including a point estimate and related disclosures?
What are the control activities relevant to the estimate? (e.g., second-person review of the computation)
Does management review prior estimates and the outcome of those estimates? How does management respond to that review?
Additionally, the auditor reviews the outcome of prior estimates for potential management bias.
If there are any significant risks (inherent risk falling toward the end of the spectrum of risk), the auditor should understand the related controls and, after that, see if they are designed appropriately and implemented.
And finally, the auditor considers if specialized skills or knowledge are needed to perform risk assessment procedures related to estimates.
Of course, after you do your risk assessment work, it's time to assess the risk.
2. Identify and Assess the Risk of Material Misstatement
SAS 143, as we have already seen, requires a separate assessment of inherent risk and control risk for each relevant assertion.
In assessing inherent risk, the auditor will consider risk factors such as complexity, subjectivity, and change. It's also important to consider the estimate method and the data used in computing management's point estimate.
Some estimates represent significant risks. So, for example, if the computation of warranty liability is complex or has a high degree of estimation uncertainty, then identify the liability as a significant risk since the valuation assertion is high risk (toward the upper end of the spectrum of inherent risk).
3. Responses to Assessed Risk of Material Misstatement
Once the assessment of risk is complete, you are in a position to create responses. As usual, document linkage from the risk level to the planned procedures. Higher risk calls for more extensive actions.
If, for example, the auditor identifies an estimate as a significant risk, go beyond basic techniques (i.e., more than a basic audit program).
Additionally, base those responses on the reasons for the assessments. In other words, create audit procedures based on the nature of the risk. Performing more procedures unrelated to the identified risk is of no help.
Three Responses to Risks Related to Estimates
The audit procedures need to include one or more of the following three steps:
Obtain audit evidence from events occurring up to the date of the auditor's report
Test how management made the accounting estimate by reviewing the following:
Methods in light of:
Potential management bias
The estimation computation (is it mathematically correct?)
Use of complex modeling, if applicable
Maintenance of the assumptions and data integrity (does this information have integrity?)
Assumptions; address the following:
Whether the assumptions are appropriate
Whether the judgments made in selecting the assumptions give rise to potential bias
Whether assumptions are consistent with each other
When applicable, whether management has the intent and ability to carry out specific courses of action
Data; address the following:
Whether the data is appropriate
Whether judgments made in selecting the data give rise to management bias
Whether the data is relevant and reliable
Whether management appropriately understands and interprets the data
Management's point estimate and related disclosure; address the following:
How management understands estimation uncertainty
See if management took appropriate steps in developing the point estimate and related disclosure
If the auditor believes management has not sufficiently addressed estimation uncertainty, the following should occur:
Request management perform additional procedures to understand the estimation uncertainty; consider disclosing more information about the estimation uncertainty
Develop an auditor's point estimate or range if management's response to the auditor's request in the prior step is not sufficient
Develop an auditor's point estimate or range; do the following:
Include procedures to evaluate whether methods, assumptions, or data are appropriate
When the auditor develops a range,
Determine whether the range includes only amounts supported by sufficient audit evidence and are reasonable in the context of the reporting framework
Review disclosures related to estimation uncertainty, design and perform procedures regarding the risk of material misstatement (i.e., determine if the disclosure provides sufficient information regarding estimation uncertainty)
Once you complete your audit work related to estimates, evaluate what you've done.
Overall Evaluation of Estimate Work
Evaluate the sufficiency of your estimate work by considering the following:
Significant judgments related to estimates and related disclosures in light of the reporting framework
Governance Communication Regarding Estimates
Finally, consider whether you should communicate estimate matters to those charged with governance, especially if a high estimation uncertainty is present.
SAS 143 Summary
While SAS 143 requires that auditors understand the estimation process and then perform procedures to ensure the reasonableness of the numbers and disclosures, there's nothing unusual about this. We gain an understanding of the estimates, assess the risk, and create responses.
Many estimates, such as plant, property, and equipment depreciation, are simple. In those areas, there's little to do. But as always, our risk assessment and responses will increase as complexity and uncertainty increase.
In this article, I explain how you can stop over auditing and wasting precious time. You’ll soon know why to leave in and what to leave out.
Are You Over Auditing?
Ten audit engagements.
Each audit file with a different risk profile.
Each with a different audit plan.
Each file begging for attention in certain areas.
This afternoon I met with two CPAs to discuss ten audits they perform. Specifically we were looking to see what needed to be done, and maybe more importantly, what was not needed.
The concern was “over auditing.”
For as long as I can remember, CPAs have asked, “what am I doing that is not necessary?”
My answer is always the same: audit areas that have a risk of material misstatement. Drop everything else.
Removing Unnecessary Audit Steps
Well, how do you know if an audit procedure is not needed?
Look at the prior year workpaper and ask, “what relevant assertion and in what transaction cycle does this procedure address?” If you can’t connect the workpaper to a risk, then it’s probably not needed.
You can “reverse engineer” an audit by looking at the prior year workpapers and asking this same question over and over again: “what risk of material misstatement does this workpaper address?”
Adding Necessary Audit Steps
Then—and more importantly—“forward engineer” the audit plan by assessing your risk for each relevant assertion and planning (and linking) a procedure to satisfy (lower) the risk of material misstatement.
Brevity of Audit File
An audit file needs to be tight, without waste.
Moreover, let it speak of the important—and nothing else. An audit file is somewhat like a good speech: There are no wasted words.
So, can excessive work papers create problems?
Excessive Work Papers Create (at least) Two Problems
Excessive (or unneeded) work papers can create problems, including:
1. Clutter (which degrades the message) 2. Legal exposure
Why do I say legal exposure? If your work papers are subpoenaed and there are unnecessary work papers, the opposing party may find contradictory information that works against you.
Then you know what would come next: the opposing attorney holding up a damning document as she asks, “did this work paper come from YOUR audit file?”
Keep things lean.
Right Audit Steps
In summary, say what needs to be said, and nothing more.
Most CPAs grapple with leases from the lessee’s point of view, so in this post, we’ll look at finance and operating leases from the lessee’s perspective. Under the new lease standard (ASC 842, Leases), what are the types of leases? Does the accounting vary based on the type of lease? Are lease expenses different?
First, let’s start by defining the types of leases and how to classify them.
The Types of Leases
Upon the commencement date of the lease, the company should classify the lease as either a finance or an operating lease using ASC 842. (Under ASC 840, a finance lease was referred to as a capital lease.)
So what is a finance lease? A lease is considered a finance lease if it meets any of the following criteria:
The lease transfers ownership of the underlying asset to the lessee by the end of the lease term
The lease grants the lessee an option to purchase the underlying asset that the lessee is reasonably certain to exercise
The lease term is for the major part of the remaining economic life of the underlying asset (today, we use the 75% rule)
The present value of the sum of the lease payments and residual value guarantee equals or exceeds substantially all of the fair value of the underlying asset (today, we use the 90% rule)
The underlying asset is of such a specialized nature that it is expected to have no alternative use to the lessor at the end of the lease term
While the bright-line criteria (e.g., the lease term of 75% or more of economic life) have been removed, the basis for conclusions in the new lease standard acknowledges some old rules of thumb. It says that one reasonable approach to determining whether the lease is for a significant portion of the asset’s life is the 75% threshold. The conclusion goes on to say that “90 percent or greater is ‘substantially all’ of the fair value of the underlying asset.” So, in effect, FASB removed the bright lines as a rule but not in principle–the conclusion says FASB “does not mandate those bright lines.”
And what is an operating lease? It’s any lease that is not a financing lease.
Accounting Similarities and Differences
Both operating and finance leases result in a right-of-use asset and a lease liability. The subsequent accounting for the two types of leases is quite different.
Finance Lease Accounting
The accounting for a finance lease–using ASC 842–is similar to capital lease accounting under ASC 840.
When a company enters a finance lease, it records the right-of-use asset and the lease liability. The amortization of the right-of-use asset will be straight-line, and the amortization of the liability will be accounted for using the effective interest method. Consequently, lease expenses are front-loaded (i.e., expenses will decline throughout the lease term). The amortization and interest expenses will be presented separately on the income statement.
As we are about to see, operating lease accounting is significantly different, particularly with regard to accounting for the lease expense and the amortization of the right-of-use asset.
Operating Lease Accounting
The primary change in lease accounting lies in the operating lease area. Under ASC 842, a company will book a right-of-use asset and a lease liability for all operating leases greater than twelve months in length (an election has to be made to exclude leases of twelve months or less). Under ASC 840, no asset or liability was recorded.
Will the operating lease expense be any different than it has been? No. But the recording and amortization of the right-of-use asset and the lease liability are new.
The Initial Operating Lease Entries
Let’s say a company has a five-year operating lease for $1,000 per month and will pay $60,000 over the life of the lease. How do we account for this lease? First, the company records the right-of-use asset and the lease liability by discounting the present value of the payments using the effective interest method. In this example, the present value might be $54,000. As the right-of-use asset and lease liability are amortized, the company will (each month) debit rent expense for $1,000—the amount the company is paying. So the expense amount is the same as it was under ASC 840.
Amortizing the Right-of-Use Asset and the Lease Liability
How does the company amortize the right-of-use asset and the lease liability? The lease liability is amortized using the effective interest method, and the interest expense is a component of the rent expense. What’s the remainder of the $1,000? The amortization of the right-of-use asset. The $1,000 rent expense comprises two parts: (1) the interest expense for the month and (2) the right-of-use amortization amount, which is a plug to make the entry balance. Even though the rent expense is made up of these two components, it appears on the income statement as one line: rent expense (unlike the finance lease, which reflects interest expense and amortization expense separately).
Due to the straight-line lease expense calculation mechanics, the right-of-use asset amortization expense is back-loaded (i.e., the amortization expense component is less in the early part of the lease). One potential consequence of this slower amortization is that the right-of-use asset is more likely be impaired (at least as compared to a financing lease). The impairment rules do apply to the right-of-use asset.
Here’s a video showing you the journal entries for financing and operating leases.
So, what do you think of the new lease accounting? Is it better? Worse?