The American Institute of CPAs’ Financial Reporting Executive Committee has submitted a comment letter to the Financial Accounting Standards Board and the International Accounting Standards Board suggesting changes in the latest proposals for lease accounting standards.

Richard Paul, who chairs the AICPA’s FinREC panel, and Chad Soares, chairman of the FinREC Leases Task Force, said they support the FASB and IASB goal of putting long-term leases on the balance sheet, but suggested in Monday’s comment letter that the classification tests to distinguish so-called Type A leases from Type B leases in the latest exposure draft should be simpler.

They acknowledged the criticisms that FASB and the IASB made back in 2009 about the current leasing standards, for example, that many leases are off-balance sheet despite the fact that financial statement users believe they give rise to assets and liabilities that should be recognized in the financial statements of lessees, forcing users to adjust the reported amounts in the financial statements in connection with those transactions. There are also two widely varying accounting models for leases, allowing similar transactions to be accounted for differently, further reducing comparability for users. In addition, the existing lease accounting standards provide transaction structuring opportunities that make the financial statements less transparent for users.

“A cornerstone of the response to these criticisms is that a lessee should recognize the assets and liabilities arising from a lease,” the FinREC officials wrote.  “We agree with this core principle and with the notion that many leases inherently include a financing component that justifies the recognition of a liability by the lessee, and the conceptual merit of recognizing the associated rights conveyed in exchange for assuming the liability.  However, FinREC is concerned that other important objectives have not been met and that the overall standard is not a sufficient improvement over today’s guidance to support adoption of the proposals in the [exposure draft].  We are also concerned that adoption of the provisions of the ED will impose significant costs on financial statement preparers—both on transition and on an ongoing basis.”

They acknowledged that some of those costs represent the investment in new accounting systems and the associated controls that could ease the financial reporting burdens once they are implemented. “However, the complexity inherent in the construct of the dual model, specifically the distinction based on whether the leased item is property, and the ongoing required judgments, represent a permanent increased level of effort,” they added. “A lease accounting model that is general enough to consider all the various types of leasing arrangements and provides a single recognition and measurement approach has proven to be a challenge. As such, we understand why the ED proposes a dual model; however, the dual model as currently proposed is not sufficiently operational and does not incrementally improve financial reporting in a cost-effective manner.”

Paul and Soares added that, in formulating a final standard, the standard-setters should give greater consideration to the cost versus the benefit, including performing additional field tests of any new standards and evaluating how to strike a better balance between the technical and operational aspects of any proposed changes to leasing. “FinREC believes that any transition to a model with most leases on balance sheet will by necessity involve a significant level of effort,” they added. “However, it would appear that additional accommodations with respect to classification, transition and remeasurement … would reduce the cost without sacrificing transparency objectives of this project.”

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