Accounting for Lease Concessions Related to COVID-19

ACCOUNTING FOR LEASE CONCESSIONS RELATED TO COVID-19

The Financial Accounting Standards Board (FASB) has provided an interpretative Q&A that provides reporting entities (lessees and lessors) with an acceptable approach to account for lease concessions related to the novel coronavirus - but only those concessions that do not result in a substantial increase in the (i) rights of the lessor or (ii) obligations of the lessee.

This elective accounting approach is available for coronavirus-related concessions that result in “the total payments required by the modified contract being substantially the same as or less than total payments required by the original contract.” That means a reporting entity can elect to apply or not to apply applicable lease modification accounting guidance – and the approach may only be applied to coronavirus-related concessions as described above. 

FASB offers two methods to account for a coronavirus-related concession granted in the form of payment deferral (i.e. only timing, not total amount, of consideration in the contract changes) when the option not to apply lease modification accounting guidance has been elected.  

• Account for a payment deferral as if there has been no change to the lease contract. Lessees and lessors would continue their current lease accounting. A payment deferral would be accounted for (a) by a lessor as an increase to its lease-related receivable on its balance sheet with continued lease-related income recognition in its income statement; and (b) by a lessee as an increase to its accounts payable with continued lease-related expense during the deferral period. 
• Account for payment deferrals as variable lease payments. Lessees and lessors would continue their current lease accounting, but would recognize a concession as it occurs. During the period for which the concession was granted: (a) a lessor would not recognize lease-related income on the lease because it would be offset by the concession; and (b) a lessee would not recognize lease-related expense because it would be offset by the concession. However, lessor and lessee balance sheets, to the extent applicable, would be adjusted accordingly. When the deferred payments are subsequently paid, lessors and lessees would recognize payments of the previously deferred amounts as incremental lease-related income and lease-related expense, respectively. 

OTHER FASB COVID-19-RELATED ITEMS:
At its April 8, 2020, meeting, the FASB discussed the following coronavirus-related accounting considerations. 

1. View 1 – Upon modification, a new effective interest rate is determined in accordance with Subtopic 310-20 that equates the revised remaining cash flows to the carrying amount of the original debt and is applied prospectively for the remaining term. Interest income is recognized from the modification date forward based on the new effective interest rate, including during the “loan payment holiday.”
2. View 2 – Upon modification, interest income on the loan should be recognized in accordance with the contractual terms. During the “loan payment holiday,” no interest income on the loan would be recognized. It would resume when the payment holiday ends.

1. When a cash flow hedge is discontinued or de-designated, a reporting entity evaluates whether the hedged forecasted transaction remains probable of occurring by the end of the time period originally specified in its hedge designation documentation or within a two-month period thereafter to determine whether related amounts deferred in accumulated other comprehensive income (AOCI) should remain there. According to FASB, “In rare cases, the existence of extenuating circumstances that are outside the control or influence of the entity may cause the forecasted transaction to be probable of occurring at a date that is beyond that additional two-month period.”
   
   In such cases, related amounts deferred in AOCI should remain there until the hedged forecasted transaction affect earnings. The FASB staff determined that COVID-19-related delays in the timing of hedged forecasted transactions could represent such extenuating circumstances. However, this exception applies only to situations in which the forecasted transaction remains probable of occurring.

PROPOSED ACCOUNTING STANDARDS UPDATE (OPEN TO PUBLIC COMMENT)
On April 21, 2020, the FASB issued a proposed Accounting Standards Update that, if finalized, would provide for the deferral of the following accounting standards: 

1. Proposed an additional one-year deferral of the effective date of Topic 842 for private companies and not-for-profits other than those described in b. below to fiscal years beginning after Dec. 15, 2021 (e.g. calendar year 2022.) 
2. Proposed one-year deferral of Topic 842 for not-for-profits that have issued or are conduit bond obligors for securities that are traded, listed, or quoted on an exchange or an over-the-counter market and which have not yet been issued financial statements to fiscal years beginning after Dec. 15, 2019 (e.g. calendar year 2020).
3. Early adoption continues to be permitted for these reporting entities.

1. Proposed one-year deferral of Topic 606 for franchisors that are not public business entities to fiscal years beginning after Dec. 15, 2019 (e.g. calendar year 2020).

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