On The Horizon - March 5, 2013

Current practice issue

Application of contract accounting, especially percentage-of-completion

Although contract accounting arose decades ago in the context of construction contracts, it may also be applied in other limited circumstances. Many entities enter into long-term contracts to provide any number of services, including services to construct or produce a tangible product, professional services in a software arrangement, and general consulting services. An important question in each case is what revenue recognition guidance applies. The answer first depends on whether the contract is within the scope of the contract accounting guidance in FASB Accounting Standards Codification® (ASC) 605-35, Revenue Recognition: Construction-Type and Production-Type Contracts.

ASC 605-35-15-6(j) states, and the SEC staff has reiterated, that entities should not apply the guidance in ASC 605-35 to service arrangements that are not included within its scope. Accordingly, an entity should apply the percentage-of-completion method only if a contract is determined to be within the scope of ASC 605-35. If a long-term service contract is outside the scope of ASC 605-35, the entity should apply a proportional performance or a completed performance model to account for the service arrangement. Under a proportional performance model, costs are generally expensed as incurred, and, as a result, applying the proportional performance model will not result in a constant margin percentage as under the percentage-of-completion method.

Contracts within the scope of ASC 605-35

ASC 605-35-15-3 lists the types of arrangements within the scope of contract accounting, which are generally construction-type or production-type contracts where services are performed to customer specifications. In addition, contract accounting is required for arrangements covering the delivery of software or a software system that includes significant production, modification, or customization of the software. Separate contracts to provide services essential to the construction or production of tangible property (for example, design, engineering, procurement, and construction management) should also be accounted for using the guidance of ASC 605-35. Third-party requirements (such as government or regulatory agency) are considered customer-specifications when evaluating the applicability of contract accounting to an arrangement.

Contracts outside the scope of ASC 605-35

• ASC 605-35-15-6 lists certain arrangements where contract accounting is not considered appropriate, including the following transactions:

• Sales of goods from inventory or sales of homogenous goods from continuing production
• Sales of goods produced in a standard manufacturing operation in the ordinary course of business and marketed using the vendor's regular marketing channels, even if the products are made to customer specifications
• Service provided over an extended period of time (for example, health club memberships)
• Magazine subscriptions
• Cost-plus-fixed-fee government contracts and other cost-plus-fee contracts, as well as contracts for products and services that are customarily billed as shipped or rendered
• Services that do not produce a tangible product as the principal intended result

Examples

Although entities must use judgment to appropriately identify when contract accounting should be applied, the following examples illustrate how to apply the scope guidance in ASC 605-35:

• Entity A provides communications network solutions. Typical arrangements include planning, migration, integration, and support services, as well as the provision of hardware and software. Entity A is a reseller of the hardware and software, and the solutions do not require customizing or modifying the software. The planning phase of the arrangements includes a customer needs assessment. The entity uses the results of the needs assessment to design a customized solution for the customer.

• Entity B is a general contractor whose projects primarily include designing and subsequently building roads, including the related site-preparation work. Entity B personnel provide project management services, and the construction services are subcontracted to third parties.

• Entity C designs and produces large simulators used in the commercial transportation industry for training and certification purposes. The simulators are produced to customer specifications in a standard manufacturing process. Entity C integrates the unique characteristics of a customer's equipment in the simulators through customized software.

FASB

All decisions reached at Board meetings are tentative and may be changed at future meetings. Decisions are included in an Exposure Draft only after a formal written ballot. Decisions reflected in Exposure Drafts are often changed in redeliberations by the Board based on information received in comment letters, at public roundtable discussions, and from other sources. Board decisions become final after a formal written ballot to issue a final Accounting Standards Update.

ASU issued on obligations resulting from joint and several liability arrangements

Recently, the FASB issued Accounting Standards Update (ASU) 2013-04, Obligations Resulting from Joint and Several Liability Arrangements for Which the Total Amount of the Obligation Is Fixed at the Reporting Date ‒ a consensus of the FASB Emerging Issues Task Force .

A summary of the ASU can be found in the January 22 edition of the On the Horizon.

FAF Trustees approve new FASB / GASB agenda-setting process

The Financial Accounting Foundation's (FAF) Board of Trustees recently approved a key change to the agenda-setting process for both the FASB and GASB. A majority of the respective Board members, rather than the Board chair alone, will now be required to approve decisions regarding project plans, agenda setting, and the priority of projects. All future agenda decisions will be voted on by Board members in public meetings. This change will provide stakeholders with greater insight into the agenda decision process, including feedback from stakeholders, the urgency of certain issues, and the availability of Board resources.

Insurance contracts discussed at meeting held February 27

The following highlights are from the FASB's February 27 discussions of its project on insurance contracts.

Presentation in the statements of financial position and comprehensive income

The Board affirmed its previous decision that an insurer would present specified items in the statement of financial position for the building block approach and the premium allocation approach. In addition, the Board tentatively decided that an insurer would also present specified items in the statement of comprehensive income.

Disclosures

The FASB reached tentative decisions about specific disclosures for insurance contracts that would be required in both annual and interim financial statements.

GASB

FAF seeks input on proposed changes to GASB agenda-setting process

Recently, the FAF's Board of Trustees released a Request for Comment, GASB's Scope of Authority: Proposed Changes to Agenda-Setting Process, which proposes revisions to the agenda-setting process of the GASB to assist the Trustees in assessing the scope of the GASB's standard-setting activity.

In May 2011 the FAF authorized an independent academic study to explore the purposes of financial accounting and reporting by state and local governments and to provide insights to the Trustees on how the GASB can best serve stakeholders. The study revealed a lack of consensus about the appropriate scope of the GASB's activities and involvement in government accountability reporting. Accordingly, the

Trustees would like stakeholder input on the proposed GASB agenda-setting process.

The comment period ends April 30, 2013.

FAF team concludes post-implementation review of GASB Statements 3 and 40

Recently, the FAF issued a Post-Implementation Review Report of GASB Statement 3, Deposits with Financial Institutions, Investments (including Repurchase Agreements), and Reverse Repurchase Agreements, and Statement 40, Deposit and Investment Risk Disclosures. These statements both require note disclosures about deposit and investment risks by state and local governments, and Statement 3 also provides accounting guidance for repurchase and reverse repurchase agreements.

The review team reached an overall conclusion that Statements 3 and 40 achieve their purpose and provide decision-useful information about deposit and investment risk to creditors and other financial statement users. The team had no significant standard-setting process recommendations.

In addition, the FAF announced that it will conduct a post-implementation review of GASB Statement 10, Accounting and Financial Reporting for Risk Financing and Related Insurance Issues, and Statement 30, Risk Financing Omnibus ‒ an amendment of GASB Statement No. 10.

AICPA

Advisory issued on audits of employee benefit plans

Recently, the AICPA's Employee Benefit Plan Audit Quality Center issued Plan Advisory, Employee Benefit Plans ‒ Financial Statement Audits, to provide plan sponsors, plan administrators, and trustees with a better understanding of, and insights into, the independent audit of the financial statements of an employee benefit plan.

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