Exposure Draft Accounting Standards Board Proposed Accounting Standards for Not-for-Profit Organizations Accounting Standards Improvements for Not-for-Profit Organizations February 2017 COMMENTS TO THE AcSB MUST BE RECEIVED BY MAY 31, 2017 Respondents are asked to email their comment letters (in a Word file) to: [email protected] Please address your comments to: Rebecca Villmann, CPA, CA, CPA (Illinois) Director, Accounting Standards Accounting Standards Board 277 Wellington Street West Toronto, Ontario M5V 3H2 This Exposure Draft reflects proposals made by the Accounting Standards Board (AcSB). Individuals and organizations are invited to send written comments on the Exposure Draft proposals. Comments are requested from those who agree with the Exposure Draft as well as from those who do not. Comments are most helpful if they are related to a specific paragraph or group of paragraphs. Any comments that express disagreement with the proposals in the Exposure Draft should clearly explain the problem and include a suggested alternative, supported by specific reasoning. All comments received by the AcSB will be available on the website shortly after the comment deadline, unless confidentiality is requested. The request for confidentiality must be stated explicitly within the response. Highlights The Accounting Standards Board (AcSB) proposes, subject to comments received following exposure, to replace: TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4431 with Section 4433; INTANGIBLE ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4432 with Section 4434; and COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4440 with Section 4441 in Part III of the CPA Canada Handbook – Accounting as part of its program of major improvements to accounting standards for not-for-profit organizations (NFPOs). The AcSB proposes that new Sections 4433, 4434 and 4441 be based on existing Sections 4431, 4432 and 4440 with proposed revisions resulting from its accounting standards improvements program. Tables of Concordance summarize the proposed changes from each of existing Sections 4431, 4432 and 4440. For an analysis of the effects of these proposals, see the “Basis for Conclusions.” Main features of the proposals The following summarizes the key features of the proposals: Tangible capital assets and intangible assets NFPOs would be directed to follow PROPERTY, PLANT AND EQUIPMENT, Section 3061, GOODWILL AND INTANGIBLE ASSETS, Section 3064, and ASSET RETIREMENT OBLIGATIONS, Section 3110 in Part II of the Handbook for tangible capital assets and intangible assets held by NFPOs, except for the guidance included in Sections 4433 and 4434 related to items such as contributed assets and write-downs of assets. Applying Section 3061 would include considering the guidance on componentization (see paragraph 3061.18). A tangible capital asset or intangible asset would be written down to its fair value or replacement cost to reflect a partial impairment of the asset when conditions indicate that the asset no longer contributes to an organization’s ability to provide goods and services, or that the value of future economic benefits or service potential associated with the asset is less than its net carrying amount. A list of indicators would provide examples of conditions that may be present to indicate impairment of tangible capital assets or intangible assets. Accounting Standards Improvements for Not-for-Profit Organizations | i NFPOs would be directed to follow the disclosure requirements in IMPAIRMENT OF LONG LIVED ASSETS, Section 3063 in Part II for impairments of tangible capital assets and intangible assets. Works of art, historical treasures and similar items not part of a collection NFPOs would continue to account for works of art, historical treasures and similar items not part of a collection as tangible capital assets, intangible assets, investments or as inventory type items depending on their intended use (i.e., in accordance with INVENTORIES HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 3032, and INVESTMENTS, Section 3051 in Part II, and Sections 4433 or 4434). Collections Collections would be recorded on the statement of financial position. An NFPO would make an accounting policy choice to record collections at cost or at nominal value and that choice would be applied to all of its collections. Guidance on determining cost would be added. A collection recorded at cost would be written down to its fair value or replacement cost to reflect partial impairment of the collection whenever events or changes in circumstances indicate that its net carrying value may exceed fair value. A list of indicators would provide examples of conditions that may be present to indicate impairment of a collection. Guidance on disposing of items in a collection would be added. For disposal of items contributed to a collection that are subject to external restrictions, the gain or loss would be accounted for in accordance with CONTRIBUTIONS — REVENUE RECOGNITION, Section 4410. However, for items in a collection that do not have external restrictions and are disposed of, the gain or loss would be recognized in the statement of operations. An NFPO would disclose whether the write-down of a collection is measured at the collection’s fair value or replacement cost. Transition Prospective application of Sections 4433 and 4434 would be required in accordance with ACCOUNTING CHANGES, paragraph 1506.05(g) in Part II, except as permitted by the transition provisions. The transition provisions would provide relief for an NFPO to: o allocate the costs of tangible capital assets to their component parts based on their relative cost or fair value at the date the assets were acquired, or at fair value or replacement cost at the date the Section is first applied; and ii | Exposure Draft – February 2017 o recognize an adjustment to opening net assets for partial impairments of tangible capital assets and intangible assets existing at the date the Section is first applied. Retrospective application of Section 4441 would be required in accordance with ACCOUNTING CHANGES, Section 1506 in Part II, except as permitted by the transition provisions. The transition provisions would provide relief for an NFPO that chooses to record its collection at cost to: o capitalize items in a collection acquired in previous periods at cost or fair value at the date of acquisition, or at fair value or replacement cost at the date the Section is first applied; o measure items in a collection at nominal value when the cost cannot be reasonably determined; and o recognize as an adjustment to opening net assets for partial impairments of collections existing at the date the Section is first applied. Consequential amendments Minor consequential amendments would be made, as required, to other standards in Part III of the Handbook. Plans for finalizing the proposals The AcSB will redeliberate the proposals in light of comments received. Part of the redeliberation process includes consultations with the AcSB’s Not-for-Profit Advisory Committee. The Committee assists the AcSB in retaining and improving accounting standards for not-for-profit organizations in Part III. The AcSB will provide updates about its redeliberations in its decision summaries and on its Accounting Standards Improvements for Not-for-Profit Organizations project page. The AcSB expects to issue the new Sections 4433, 4434 and 4441 in the second quarter of 2018, if no significant changes are required to the proposals after deliberating the comments received. In that case, the proposed effect date of the amendments would be for fiscal years beginning on or after January 1, 2019. Comments requested Comments are most helpful if they are related to a specific paragraph or group of paragraphs. Any comments that express disagreement with the proposals in the Exposure Draft should clearly explain the problem and include a suggested alternative, supported by specific reasoning. Accounting Standards Improvements for Not-for-Profit Organizations | iii While the AcSB welcomes comments on all changes proposed in this Exposure Draft, it particularly welcomes comments on the questions listed below. 1. Do you agree that NFPOs should be directed to follow PROPERTY, PLANT AND EQUIPMENT, Section 3061, IMPAIRMENT OF LONG LIVED ASSETS, Section 3063, GOODWILL AND INTANGIBLE ASSETS, Section 3064, and ASSET RETIREMENT OBLIGATIONS, Section 3110 in Part II of the Handbook for tangible capital assets and intangible assets held by NFPOs, except for the guidance included in Sections 4433 and 4434 (see paragraphs 4433.01 and 4434.01)? If not, why not? 2. Tangible capital assets, intangible assets and collections would be written down to their fair value or replacement cost to reflect partial impairments. Do you agree with the following: (a) Tangible capital assets, intangible assets and collections should be written down to reflect partial impairments (see paragraphs 4433.16, 4434.06 and 4441.10). If not, why not? (b) Tangible capital assets, intangible assets and collections should be written down to their fair value or replacement cost (see paragraphs 4433.16, 4434.06 and 4441.10). If not, what value? (c) The list of indicators, which provide examples of conditions that may indicate impairment, would be helpful (see paragraphs 4433.18, 4434.08 and 4441.11). If not, why not? 3. Do you foresee issues specific to NFPOs being required to consider the guidance in PROPERTY, PLANT AND EQUIPMENT, paragraph 3061.18 in Part II on componentization for tangible capital assets? If so, what are they? 4. Do you agree that collections should be recorded on the statement of financial position at cost or nominal value (see paragraph 4441.06)? If not, why not? 5. Do you think the proposals in Section 4441 would result in NFPOs reporting multiple collections? If so, what would be the rationale for reporting multiple collections? 6. Do you think that NFPOs with multiple collections should be permitted to value each collection differently (see paragraph 4441.06)? Why or why not? 7. In accordance with the definition of a collection in Section 4441, the proceeds on disposal of items in a collection must be used to acquire more items in the collection or maintain the existing collection. (a) Do you agree that on disposal of one or more items in a collection, whether by sale, destruction, loss or expropriation, the difference between the net proceeds on disposal and the net carrying amount should be recognized: iv | Exposure Draft – February 2017 (i) in accordance with CONTRIBUTIONS — REVENUE RECOGNITION, Section 4410 for items contributed to a collection that are subject to external restrictions (see paragraph 4441.12); or (ii) in the statement of operations for items in a collection that are not subject to external restrictions (see paragraph 4441.12)? If not, how should it be recognized? (b) How do you report cash received on disposal of items in a collection prior to acquiring more items or maintaining the existing collection (i.e., is the restricted cash separately identified on the statement of financial position or disclosed in the notes)? (c) CASH FLOW STATEMENT, paragraph 1540.44 in Part II, requires disclosure of the amount of cash and cash equivalents for which the use is restricted. Are the disclosure requirements in paragraphs 1540.44 and 4441.14(e) adequate to inform users when the proceeds on disposal of items in a collection are internally restricted (i.e., must be used to acquire more items or maintain the existing collection) or externally restricted (i.e., donor stipulations on contributed items?) If not, what additional requirements are needed? 8. It is proposed that Sections 4433 and 4434 be applied prospectively in accordance with ACCOUNTING CHANGES, Section 1506 in Part II and with special transitional provisions. Do you agree with the following: (a) Sections 4433 and 4434 should be applied prospectively (see paragraphs 4433.26 and 4434.15). If not, why not? (b) NFPOs should be permitted to recognize an adjustment to opening net assets at the date Sections 4433 and 4434 are first applied, to reflect partial impairments of tangible capital assets and intangible assets existing at that date (see paragraphs 4433.29 and 4434.17). If not, why not? (c) NFPOs should be permitted to allocate the costs of tangible capital assets to their component parts based on: cost or fair value at the date of acquisition, or fair value or replacement cost at the date the Section is first applied (see paragraph 4433.28). If not, why not? 9. It is proposed that Section 4441 be applied retrospectively in accordance with ACCOUNTING CHANGES, Section 1506 in Part II and with special transitional provisions. (a) Do you agree that Section 4441 should be applied retrospectively (see paragraph 4441.19)? If not, why not? (b) Do you agree with the proposed transition relief for measuring collections at cost (see paragraphs 4441.21-.22)? If not, why not? Accounting Standards Improvements for Not-for-Profit Organizations | v (c) Do you think the proposed transition relief for measuring collections at cost will encourage more NFPOs to use the cost method? If not, what would make a transition to the cost method easier? 10. Do you agree with the proposed effective date (i.e., fiscal years beginning on or after January 1, 2019) (see paragraphs 4433.26, 4434.15, and 4441.19)? If not, why not? 11. Given that many NFPOs have March 31st fiscal year ends, would an effective date of April 1st be preferable for these and future proposals? Why or why not? 12. Do NFPOs need more than one year to implement the proposed changes in Section 4433, 4434 and 4441? If so, how long and why? The deadline for providing your comment letter to the AcSB is May 31, 2017. You may email your comments (in a Word file) to: [email protected]. vi | Exposure Draft – February 2017 Table of Concordance — Tangible Capital Assets Held by Not-for-Profit Organizations The following table indicates the correspondence between the proposed new Section 4433 and the existing Section 4431. Comments have been included to describe substantive changes (i.e., changes in current practice). Minor changes include removing guidance that duplicates guidance contained in Part II, updating section reference numbers and editorial changes. Paragraph(s) in proposed Section 4433 Paragraph(s) in existing Section 4431 No change Changes Minor .01 .01 .02 .02 .03-.04 .03-.04 .05 .05 .06 Comments Substantive X Adds guidance to direct NFPOs to Part II .06 X Adds definition of “replacement cost”. .07 .07 X Clarifies what is included in the cost of a contributed tangible capital asset. .08 .08 .09 .09 X Explains what is included in the cost of a contributed tangible capital asset. .10 .10 .11 .11 — .12-.13 X .12 .14 X — .15-.20 X .13 .21 X .14 .22 — .23-.24 X .01 .25 X X X X X X X X Accounting Standards Improvements for Not-for-Profit Organizations | vii Paragraph(s) in proposed Section 4433 Paragraph(s) in existing Section 4431 No change Changes Minor Comments Substantive .16 .26 X Removes guidance that required full impairment and adds guidance that requires partial impairment .17 — X Provides guidance on the concepts “future economic benefits” and “service potential” .18 — X Adds examples of indicators of impairment .19 .27 X Removes guidance related to full impairment .20 .28 — .29-.33 .21 — X Adds a disclosure requirement for partial impairment measurement basis .15 .34 .22-.24 .35-.37 .25 .38 .26 .39 X Identifies effective date .27-.29 — X Provides transition guidance viii | Exposure Draft – February 2017 X X X X X Table of Concordance — Intangible Assets Held by Not-for-Profit Organizations The following table indicates the correspondence between the proposed new Section 4434 and the existing Section 4432. Comments have been included to describe substantive changes (i.e., changes in current practice). Minor changes include removing guidance that duplicates guidance contained in Part II, updating section reference numbers and editorial changes. Paragraph(s) in proposed Section 4434 Paragraph(s) in existing Section 4432 No change Changes Minor .01 .01 .02-.03 .02-.03 .04 .04 .05 .05 — Comments Substantive X Adds guidance to direct NFPOs to Part II .06 X Removes guidance that directed NFPOs to Part II for writedowns .06 .07 X Removes guidance that required full impairment and adds guidance that requires partial impairment .07 — X Provides guidance on the concepts “future economic benefits” and “service potential” .08 — X Adds examples of indicators of impairment .09 .08 X Removes guidance that required full impairment .11 — X Adds a disclosure requirement for partial impairment measurement basis .10 .09 X .11-.14 .10-.12 X X X X Accounting Standards Improvements for Not-for-Profit Organizations | ix Paragraph(s) in proposed Section 4434 Paragraph(s) in existing Section 4432 No change Changes Minor Comments Substantive .15 .13 X Identifies effective date .16-.17 — X Provides transition guidance x | Exposure Draft – February 2017 Table of Concordance — Collections Held by Not-for-Profit Organizations The following table indicates the correspondence between the proposed new Section 4441 and the existing Section 4440. Comments have been included to describe substantive changes (i.e., changes in current practice). Minor changes include removing guidance that duplicates guidance contained in Part II, updating section reference numbers and editorial changes. Paragraph(s) in proposed Section 4441 Paragraph(s) in existing Section 4440 No change Changes Minor .01 .01 .02 .02 .03 .03 .04 .04 .05 .05 — Comments Substantive X Expands scope to include measurement and disclosure of collections X Adds definitions of “cost” and “fair value” .06 X Deleted as a result of requiring collections be recognized .06 — X Adds guidance to require collections be recognized at cost or nominal value .07-.08 — X Adds guidance for determining cost .09 — X Adds amortization guidance .10 — X Adds guidance requiring partial impairment .11 — X Adds examples of indicators of impairment .12 — X Adds guidance for disposal of items in a collection X X X Accounting Standards Improvements for Not-for-Profit Organizations | xi Paragraph(s) in proposed Section 4441 Paragraph(s) in existing Section 4440 No change Changes Minor Comments Substantive .13 — X Adds presentation requirement for collections recognized .14 .07 X Adds disclosure requirements for partial impairments .15 .08 .16 .09 .17 .10 .18 .11 .19 .12 X Identifies effective date .20-.22 — X Provides transition guidance xii | Exposure Draft – February 2017 X X X X Tangible Capital Assets Held by Not-for-Profit Organizations, Section 4433 TABLE OF CONTENTS Paragraph Purpose and scope ......................................................................... .01-.05 Definitions ........................................................................................ .06 Recognition and measurement ...................................................... .07-.20 Cost ........................................................................................... .07-.13 Amortization ............................................................................... .14-.15 Write-downs ............................................................................... .16-.19 Disposal ..................................................................................... .20 Presentation and disclosure .......................................................... .21-.24 Contributed tangible capital assets ........................................... .22-.24 Tangible capital assets held by small organizations .................. .25 Effective date ................................................................................... .26-.29 PURPOSE AND SCOPE .01 This Section deals with accounting for tangible capital assets held by not-forprofit organizations. Except as otherwise provided in this Section: (a) tangible capital assets are accounted for in accordance with PROPERTY, PLANT AND EQUIPMENT, Section 3061 in Part II of the Handbook; (b) disclosures for impairments of tangible capital assets are accounted for in accordance with IMPAIRMENT OF LONG-LIVED ASSETS, Section 3063 in Part II; (c) obligations associated with the retirement of capital assets are accounted for in accordance with ASSET RETIREMENT OBLIGATIONS, Section 3110 in Part II; (d) intangible assets acquired or developed by not-for-profit organizations are accounted for in accordance with INTANGIBLE ASSETS HELD BY NOT-FORPROFIT ORGANIZATIONS, Section 4434; and (e) items held as part of a collection are accounted for in accordance with COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4441. .02 This Section applies to tangible capital assets recognized under LEASES, Section 3065 in Part II of the Handbook. Accounting Standards Improvements for Not-for-profit-Organizations | 1 .03 Organizations may limit the application of this Section to the requirements in paragraph 4433.25 if the average of annual revenues recognized in the statement of operations for the current and preceding period of the organization and any entities it controls is less than $500,000. .04 The Accounting Standards Board encourages even those organizations meeting the criterion in paragraph 4433.03 to follow all of the requirements of this Section. However, the Accounting Standards Board recognizes that there are numerous small not-for-profit organizations for which this would be difficult and costly. Those organizations that meet the criterion in paragraph 4433.03 and for which the cost of following all of the requirements of this Section may exceed the benefits, may choose to provide only the disclosure required by paragraph 4433.25. Once an organization fails to meet the criterion in paragraph 4433.03, it is expected that it would continue to follow all the requirements of this Section, even if average revenues subsequently fall below $500,000. .05 Organizations that capitalize their tangible capital assets follow all other relevant provisions of this Section and other relevant Handbook Sections and thus capitalize all classes of tangible capital assets, amortize and write down those assets in accordance with this and other relevant Handbook Sections. DEFINITIONS .06 The following terms are used in this Section with the meanings specified. (a) Not-for-profit organizations are entities, normally without transferable ownership interests, organized and operated exclusively for social, educational, professional, religious, health, charitable or any other not-forprofit purpose. A not-for-profit organization's members, contributors and other resource providers do not, in such capacity, receive any financial return directly from the organization. (b) Tangible capital assets are identifiable tangible assets that meet all of the following criteria: (i) are held for use in the provision of services, for administrative purposes, for production of goods or for the maintenance, repair, development or construction of other tangible capital assets; 2 | Exposure Draft – February 2017 (ii) have been acquired, constructed or developed with the intention of being used on a continuing basis; (iii) are not intended for sale in the ordinary course of operations; and (iv) are not held as part of a collection (see COLLECTIONS HELD BY NOTFOR-PROFIT ORGANIZATIONS, Section 4441). Examples of tangible capital assets include land, buildings and equipment. (c) Cost for a contributed tangible capital asset is deemed to be fair value at the date of contribution plus all costs directly attributable to the acquisition including installing it at the location and in the condition necessary for its intended use. (d) Fair value is the amount of the consideration that would be agreed upon in an arm's length transaction between knowledgeable, willing parties who are under no compulsion to act. (e) Replacement cost is the amount that would be needed currently to acquire an equivalent asset. (f) Useful life is the estimate of the period over which a tangible capital asset is expected to be used by an organization or the number of production or similar units that can be obtained from the capital asset by the organization. The life of a tangible capital asset may extend beyond its useful life to an organization. The life of a tangible capital asset is normally the shortest of the physical, technological and legal life. RECOGNITION AND MEASUREMENT Cost .07 For a contributed tangible capital asset, cost is deemed to be fair value at the date of contribution plus all costs directly attributable to the acquisition of the tangible capital asset. Fair value may be estimated using market or appraisal values. In unusual circumstances when fair value cannot be reasonably determined, the tangible capital asset and the related contribution shall be recorded at nominal value. .08 Contributed tangible capital assets represent significant economic resources for many not-for-profit organizations. Without contributed tangible capital assets, many organizations would not be able to provide the same level of service without incurring other expenses, such as rent. Therefore, recognizing contributed tangible capital assets on the organization's statement of financial position provides financial statement users with information that is important for assessing the organization's ability to continue to achieve its service objectives. .09 The cost of a contributed tangible capital asset includes its fair value plus all other costs directly attributable to the acquisition, such as installation costs, design and engineering fees, legal fees, survey costs, site preparation costs, freight charges, transportation costs and duties. Accounting Standards Improvements for Not-for-profit-Organizations | 3 .10 Organizations may receive substantial contributions of tangible capital assets. Recognition of contributions of tangible capital assets helps provide an understanding of the resources available to the organization and enables users of the financial statements to make comparisons with other organizations. .11 A tangible capital asset purchased by a not-for-profit organization at substantially below fair value would also be recognized at its fair value with the difference between the consideration paid for the tangible capital asset and fair value reported as a contribution (see CONTRIBUTIONS – REVENUE RECOGNITION, Section 4410). Construction or development over time .12 The cost of a tangible capital asset that is developed or constructed by an organization might include contributed materials or labour, which would be recognized at fair value at the date of contribution. Certain works of art and historical treasures .13 Certain works of art and historical treasures may have lives that are so long as to be virtually unlimited. Works of art and historical treasures in this category are those that have cultural, aesthetic, or historical value that is worth preserving perpetually. In addition, the organization must have the technological and financial ability to continue to protect and preserve them. Works of art and historical treasures of this type would not be amortized. Amortization .14 When a fund accounting basis of reporting is used, the choice of the fund or funds to which amortization expense would be charged would be based on providing the most meaningful presentation (see FINANCIAL STATEMENT PRESENTATION BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4400). Some organizations may wish to show amortization as an expense of the operating fund. This presentation emphasizes that amortization is part of the cost of service delivery. Other organizations may prefer to show amortization as an expense of the tangible capital asset or plant fund. This presentation shows all revenues and expenses associated with tangible capital assets in a single fund. .15 Tangible capital assets not being amortized would include works of art and historical treasures discussed in paragraph 4433.13, or tangible capital assets under construction or development. They may also include capital assets removed from service for an extended period of time. 4 | Exposure Draft – February 2017 Write-downs .16 When conditions indicate that a tangible capital asset no longer contributes to an organization’s ability to provide goods and services, or that the value of future economic benefits or service potential associated with the tangible capital asset is less than its net carrying amount, the net carrying amount of the tangible capital asset shall be written down to the asset’s fair value or replacement cost. The write-downs of tangible capital assets shall be accounted for as expenses in the statement of operations. A write-down shall not be reversed. .17 A not-for-profit organization may hold tangible capital assets whose future economic benefits or service potential are not directly related to their ability to generate net cash flows. In these cases, the future economic benefits or service potential of the tangible capital assets for financial reporting purposes is represented by the amount the organization would need to pay to acquire the economic benefits or service potential if this was necessary to achieve the objectives of the organization. .18 Examples of conditions that may indicate that the future economic benefits or service potential associated with a tangible capital asset have been reduced and a write-down is appropriate include, but are not restricted to: (a) a significant decrease in, or cessation of, the need for the services provided by the tangible capital asset; (b) a significant adverse change in the extent or manner in which it is being used or in its physical condition; (c) a significant adverse change in legal factors or in the operating environment that could affect its value, including an adverse action or assessment by a regulator; (d) an accumulation of costs significantly in excess of the amount originally expected for its acquisition or construction; (e) a current expectation that, more likely than not, it will be sold or otherwise disposed of significantly before the end of its previously estimated useful life ("more likely than not" means a level of likelihood that is more than 50 percent); and (f) a significant decrease in its market price. There may also be other indications that the future economic benefits or service potential associated with a tangible capital asset may have been reduced. Accounting Standards Improvements for Not-for-profit-Organizations | 5 .19 When a tangible capital asset's carrying amount is written down, a corresponding amount of any unamortized deferred contributions related to the capital asset would be recognized as revenue, provided that all restrictions have been complied with (see CONTRIBUTIONS — REVENUE RECOGNITION, Section 4410). Disposal .20 On disposal of a tangible capital asset, whether by sale, destruction, loss, abandonment or expropriation, the difference between the net proceeds on disposal and the net carrying amount is recognized in the statement of operations. Any unamortized deferred contributions related to the tangible capital asset disposed of would be recognized as revenue in the period of the disposal, provided that all restrictions have been complied with (see CONTRIBUTIONS — REVENUE RECOGNITION, Section 4410). PRESENTATION AND DISCLOSURE .21 An organization shall disclose whether the write down recognized in accordance with paragraph 4433.16 is measured at the asset’s fair value or replacement cost. Contributed tangible capital assets .22 The nature and amount of contributed tangible capital assets received in the period and recognized in the financial statements shall be disclosed. .23 Information shall be disclosed about contributed tangible capital assets recognized at nominal value. .24 A contributed tangible capital asset is recognized at nominal value in the financial statements of a not-for-profit organization when its fair value at the date of contribution cannot be reasonably determined. Information about such tangible capital assets helps provide an understanding of the organization's economic resources. This information would likely include any details about the assets that would affect their usefulness to the organization: their ages, locations, present or potential uses and estimated remaining useful lives. TANGIBLE CAPITAL ASSETS HELD BY SMALL ORGANIZATIONS .25 Organizations meeting the criterion in paragraph 4433.03 and not following the other requirements of this Section shall disclose the following: (a) the policy followed in accounting for tangible capital assets; (b) information about major categories of tangible capital assets not recorded in the statement of financial position, including a description of the assets; and 6 | Exposure Draft – February 2017 (c) if tangible capital assets are expensed when acquired, the amount expensed in the current period. EFFECTIVE DATE AND TRANSITION .26 This Section applies to annual financial statements relating to fiscal years beginning on or after January 1, 2019. A not-for-profit organization applies this Section prospectively, as defined in ACCOUNTING CHANGES, paragraph 1506.05(g) in Part II of the Handbook, except as specified in paragraphs 4433.28-.29. Earlier application is permitted. .27 A not-for-profit organization can only apply paragraphs 4433.28-.29 when preparing its annual financial statements relating to the first fiscal year in which this Section is effective. .28 A not-for-profit organization that applies this Section for the first time is permitted to apply the requirements for componentization in PROPERTY, PLANT AND EQUIPMENT, paragraph 3061.18, to tangible capital assets held at the date this Section is first applied by allocating the costs of tangible capital assets and related amortization to their component parts based on their relative: (a) cost or fair value at the date the assets were acquired; or (b) fair value or replacement cost at the date this Section is first applied. A not-for-profit organization can use whichever value is deemed most practical. .29 In accordance with paragraph 4433.16, a not-for-profit organization that applies this Section for the first time is permitted to recognize an adjustment to opening net assets at the date this Section is first applied to reflect partial impairments of tangible capital assets existing at that date. Accounting Standards Improvements for Not-for-profit-Organizations | 7 Intangible Assets Held by Not-for-Profit Organizations, Section 4434 TABLE OF CONTENTS Paragraph Purpose and scope ......................................................................... .01-.04 Definitions ........................................................................................ .05 Recognition and measurement ...................................................... .06-.10 Write-downs ............................................................................... .06-.09 Contributed intangible assets .................................................... .10 Presentation and disclosure .......................................................... .11-.14 Contributed intangible assets .................................................... .12-.14 Effective date ................................................................................... .15-.17 PURPOSE AND SCOPE .01 This Section deals with accounting for intangible assets acquired or developed by a not-for-profit organization. Except as otherwise provided in this Section, a not-for-profit organization applies GOODWILL AND INTANGIBLE ASSETS, Section 3064 and the disclosure requirements in IMPAIRMENT OF LONG-LIVED ASSETS, Section 3063 in Part II of the Handbook, to such assets. .02 Organizations may limit the application of this Section to the requirements in TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, paragraph 4433.25, when the average of annual revenues recognized in the statement of operations for the current and preceding period of the organization and any entities it controls is less than $500,000. .03 The Accounting Standards Board encourages even those organizations meeting the criterion in paragraph 4434.02 to follow all of the requirements of this Section. However, the Accounting Standards Board recognizes that there are numerous small not-for-profit organizations for which this would be difficult and costly. Those organizations that meet the criterion in paragraph 4434.02 and for which the cost of following all of the requirements of this Section may exceed the benefits, may choose to provide only the disclosure required by TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, paragraph 4433.25. Once an organization fails to meet the criterion in paragraph 4434.02, it is expected that it would continue to follow all the requirements of this Section, even if average revenues subsequently fall below $500,000. .04 Organizations that capitalize their intangible assets follow all other relevant provisions of this Section and other relevant Handbook Sections and thus 8 | Exposure Draft – February 2017 capitalize all classes of intangible assets, amortize and write down those assets in accordance with this and other relevant Handbook Sections. DEFINITIONS .05 The following terms are used in this Section with the meanings specified: (a) an intangible asset is defined as an identifiable non-monetary asset without physical substance; and (b) the terms defined in TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4433.06, are used in this Section with the meanings specified in Section 4433. RECOGNITION AND MEASUREMENT Write-downs .06 When conditions indicate that an intangible asset no longer contributes to an organization’s ability to provide goods and services, or that the value of future economic benefits or service potential associated with the intangible asset is less than its net carrying amount, the net carrying amount of the intangible asset shall be written down to the asset’s fair value or replacement cost. The write-downs of intangible assets shall be accounted for as expenses in the statement of operations. A write-down shall not be reversed. .07 A not-for-profit organization may hold intangible assets whose future economic benefits or service potential are not directly related to their ability to generate net cash flows. In these cases, the future economic benefits or service potential of the intangible assets for financial reporting purposes is reflected by the amount the organization would need to pay to acquire the economic benefits or service potential if this was necessary to achieve the objectives of the organization. .08 Examples of conditions that may indicate that the future economic benefits associated with an intangible asset have been reduced and a write-down is appropriate include, but are not restricted to: (a) a significant decrease in, or cessation of, the need for the services provided by the intangible asset; (b) a significant adverse change in the extent or manner in which it is being used; (c) a significant adverse change in legal factors or in the operating environment that could affect its value, including an adverse action or assessment by a regulator; Accounting Standards Improvements for Not-for-profit-Organizations | 9 (d) an accumulation of costs significantly in excess of the amount originally expected for its acquisition or development; (e) a current expectation that, more likely than not, it will be sold or otherwise disposed of significantly before the end of its previously estimated useful life ("more likely than not" means a level of likelihood that is more than 50 percent); and (f) a significant decrease in its market price. There may also be other indications that the future economic benefits or service potential associated with an intangible asset may have been reduced. .09 When an intangible asset's carrying amount is written down, a corresponding amount of any unamortized deferred contributions related to the intangible asset is recognized as revenue, provided that all restrictions have been complied with (see CONTRIBUTIONS — REVENUE RECOGNITION, Section 4410). Contributed intangible assets .10 Organizations may receive contributions of intangible assets. Recognition of contributions of intangible assets helps provide an understanding of the resources available to the organization and enables users of the financial statements to make comparisons with other organizations. A contributed intangible asset would be recognized at its fair value at the date of contribution. Fair value of a contributed intangible asset may be estimated using market or appraisal values. When an estimate of fair value cannot reasonably be made, both the intangible asset and the related contribution would be recognized at nominal value. PRESENTATION AND DISCLOSURE .11 An organization shall disclose whether the write-down recognized in accordance with paragraph 4434.06 is measured at the asset’s fair value or replacement cost. Contributed intangible assets .12 The nature and amount of contributed intangible assets received in the period and recognized in the financial statements shall be disclosed. .13 10 | Exposure Draft – February 2017 Information shall be disclosed about contributed intangible assets recognized at nominal value. .14 A contributed intangible asset is recognized at nominal value in the financial statements of a not-for-profit organization when its fair value at the date of contribution cannot be reasonably determined. Information about such intangible assets helps provide an understanding of the organization's economic resources. This information would likely include any details about the assets that would affect their usefulness to the organization: their ages, present or potential uses and estimated remaining useful lives. EFFECTIVE DATE AND TRANSITION .15 This Section applies to annual financial statements relating to fiscal years beginning on or after January 1, 2019. A not-for-profit organization applies this Section prospectively, as defined in ACCOUNTING CHANGES, paragraph 1506.05(g) in Part II of the Handbook, except as specified in paragraph 4434.17. Earlier application is permitted. .16 A not-for-profit organization can only apply paragraph 4434.17 when preparing its annual financial statements relating to the first fiscal year in which this Section is effective. .17 In accordance with paragraph 4434.06, a not-for-profit organization that applies this Section for the first time is permitted to recognize an adjustment to opening net assets at the date this Section is first applied to reflect partial impairments of intangible assets existing at that date. Accounting Standards Improvements for Not-for-profit-Organizations | 11 Collections Held by Not-for-Profit Organizations, Section 4441 TABLE OF CONTENTS Paragraph Purpose and scope ......................................................................... .01-.02 Definitions ........................................................................................ .03 Nature of collections ....................................................................... .04-.05 Recognition and measurement ...................................................... .06-.11 Cost or nominal value ................................................................ .06-.08 Amortization ............................................................................... .09 Write-downs ............................................................................... .10-.11 Disposal............................................................................................ .12 Presentation and disclosure .......................................................... .13-.18 Effective date and transition .......................................................... .19-.22 PURPOSE AND SCOPE .01 This Section deals with accounting for collections held by not-for-profit organizations. .02 Works of art, historical treasures and similar items that are not part of a collection are dealt with in INVENTORIES HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 3032, INVESTMENTS, Section 3051 in Part II of the Handbook, TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4433, or INTANGIBLE ASSETS HELD BY NOT-FORPROFIT ORGANIZATIONS, Section 4434, based on their intended use. DEFINITIONS .03 The following terms are used in this Section with the meanings specified: (a) Not-for-profit organizations are entities, normally without transferable ownership interests, organized and operated exclusively for social, educational, professional, religious, health, charitable or any other not-forprofit purpose. A not-for-profit organization's members, contributors and other resource providers do not, in such capacity, receive any financial return directly from the organization. (b) Collections are works of art, historical treasures or similar assets that are: (i) held for public exhibition, education or research; (ii) protected, cared for and preserved; and 12 | Exposure Draft – February 2017 (iii) subject to an organizational policy that requires any proceeds from their sale to be used to acquire other items to be added to the collection or for the direct care of the existing collection. (c) Cost is the amount of consideration given up to acquire items making up the collection and includes all costs directly attributable to the acquisition of the collection. For contributed items, cost is deemed to be fair value at the date of contribution plus all costs directly attributable to the acquisition of items in the collection. (d) Fair value is the amount of the consideration that would be agreed upon in an arm's length transaction between knowledgeable, willing parties who are under no compulsion to act. NATURE OF COLLECTIONS .04 Although items meeting the definition of a collection exhibit the characteristics of assets set out in FINANCIAL STATEMENT CONCEPTS FOR NOT-FOR-PROFIT ORGANIZATIONS, Section 1001, they are excluded from the definition of capital assets. Collections are made up of items that are often rare and unique. They have cultural and historical significance. Although collections are usually held by museums or galleries, other organizations may also have items that meet the definition of a collection. For example, an organization's library may include rare books that may be considered to be a collection for purposes of this Section. The regular library materials, however, would not usually meet the definition of a collection. .05 Organizations holding collections act as custodians for the public interest. They undertake to protect and preserve the collection for public exhibition, education or research. The existence of a policy requiring that any proceeds on the sale of collection items be used to acquire additional items or for the direct care of the collection provides evidence of the organization's commitment to act as custodian of the collection. RECOGNITION AND MEASUREMENT Cost or nominal value .06 A collection shall be recorded on the statement of financial position at either cost or nominal value. For items contributed to a collection, cost is deemed to be fair value at the date of contribution plus all costs directly attributable to the acquisition of the items in the collection. Fair value may be estimated using market or appraisal values. When fair value cannot be reasonably determined, the items contributed to a collection shall be recorded at nominal value. A notfor-profit organization shall account for all collections using the same method. .07 The cost of a collection is made up of: Accounting Standards Improvements for Not-for-profit-Organizations | 13 (a) the purchase price of acquired items; (b) the fair value of contributed items; plus (c) all other costs directly attributable to the acquisition of the items making up the collection such as installation costs, design and engineering fees, legal fees, survey costs, site preparation costs, freight charges, transportation costs and duties. The cost incurred in protecting and preserving items in a collection is a repair or maintenance and should be expensed. .08 An item of a collection purchased by a not-for-profit organization at substantially below fair value would be recognized at its fair value with the difference between the consideration paid for the item and fair value reported as a contribution. Amortization .09 A collection is not subject to amortization due to the nature of collections, which requires an organization to preserve these assets in perpetuity. Write-downs .10 The value of a collection that is recorded on the statement of financial position at cost shall be written down whenever events or changes in circumstances indicate that its net carrying amount may exceed its fair value. The net carrying amount of the collection shall be written down to its fair value or replacement cost. The write-down shall be recognized as an expense in the statement of operations. A write-down shall not be reversed. .11 Examples of events or changes in circumstances that may indicate that the net carrying amount of a collection may exceed its fair value and a write-down is appropriate include, but are not restricted to: (a) a significant adverse change in the extent or manner in which it is being used or in its physical condition; (b) a significant adverse change in legal factors or in the operating environment that could affect its value; (c) an accumulation of costs significantly in excess of the amount originally expected for its acquisition or construction; and (d) a significant decrease in its market price when readily determinable. There may also be other indications that the net carrying amount of a collection may exceed its fair value. 14 | Exposure Draft – February 2017 DISPOSAL .12 On disposal of items contributed to a collection that are subject to external restrictions, the difference between the net proceeds on disposal and the net carrying amount is recognized in accordance with CONTRIBUTIONS — REVENUE RECOGNITION, Section 4410. For items in a collection that are not subject to external restrictions and are disposed of, whether by sale, destruction, loss or expropriation, the difference between the net proceeds on disposal and the net carrying amount is recognized in the statement of operations. PRESENTATION AND DISCLOSURE .13 The amount recognized as a collection shall be presented on a separate line in the statement of financial position. .14 A not-for-profit organization shall disclose the following: (a) a description of its collection; (b) the accounting policies followed with respect to the measurement of its collection; (c) details of any significant changes to the collection in the period; (d) the amount of expenditures on collection items in the period; (e) proceeds of any disposals of collection items in the period and how the proceeds were used; and (f) in the period in which a write-down is recognized: (i) a description of the facts and circumstances leading to the write-down; (ii) whether the write-down is measured at the asset’s fair value or replacement cost; and (iii) if not separately presented in the statement of operations, the amount of the impairment loss from the write-down and the caption in the statement of operations that includes that loss. .15 A description of the organization's collection may include the number and nature of items held or on display, including their relative significance. For large, diverse collections, such disclosure may take the form of a description by major categories, rather than by individual items. .16 Accounting policies related to the measurement of collections may vary from organization to organization. Disclosure of the organization's accounting policies with respect to collections would include whether the collection is recognized in the statement of financial position at cost or at nominal value. Accounting Standards Improvements for Not-for-profit-Organizations | 15 This disclosure would also state how contributed and purchased collection items are accounted for. .17 Changes in the collection resulting from acquisitions and disposals would also be disclosed. The disclosure would include a description of significant items acquired during the period and, where known, the fair values of contributed items. Also, the disclosure would include a description of significant items sold, given away, damaged, destroyed, lost or otherwise disposed of during the period. For larger collections with many changes to report, the disclosure may be provided by major category, rather than by individual item. .18 According to the definition of collections, proceeds from the sale of collection items would be used either to acquire new items for the collection or for the direct care of the collection. In accordance with paragraph 4441.14, the organization would disclose how any proceeds on the sale of collection items were used. If not all of the proceeds on sales have been used either to acquire new items for the collection or for the direct care of the collection by the reporting date, the organization would disclose how it plans to use the proceeds. EFFECTIVE DATE AND TRANSITION .19 This Section applies to annual financial statements relating to fiscal years beginning on or after January 1, 2019. A not-for-profit organization applies this Section retrospectively, in accordance with ACCOUNTING CHANGES, Section 1506 in Part II of the Handbook, except as specified in paragraphs 4441.21-.22. Earlier application is permitted. .20 A not-for-profit organization can only apply paragraphs 4441.21-.22 when preparing its annual financial statements relating to the first fiscal year in which this Section is effective. .21 When a not-for-profit organization applies the accounting policy choice to account for its collections at cost as set out in paragraph 4441.06 and applies this Section for the first time, a not-for-profit organization is permitted to capitalize retrospectively the items in a collection acquired in previous periods and held at the date this Section is applied at their: (a) cost or fair value at the date of acquisition; or (b) fair value or replacement cost at the date this Section is first applied. A not-for-profit organization uses whichever value is deemed most practical. When the cost of one or more items in a collection cannot be reasonably determined, the item(s) are recorded at nominal value, which does not preclude the remaining items in the collection from being recorded at cost. 16 | Exposure Draft – February 2017 .22 In accordance with paragraph 4441.10, a not-for-profit organization that applies this Section for the first time is permitted to recognize an adjustment to opening net assets at the date this Section is first applied to reflect partial impairments of collections existing at that date. Accounting Standards Improvements for Not-for-profit-Organizations | 17 Basis for Conclusions INTRODUCTION 1 In accordance with the AcSB’s strategy to retain and improve accounting standards for not-for-profit organizations (NFPOs) in Part III of the CPA Canada Handbook – Accounting, the AcSB is proposing amendments relating to assets held by NFPOs. In developing these proposals, the AcSB has considered the feedback from private sector stakeholders to its April 2013 joint AcSB/Public Sector Accounting Board (PSAB) Statement of Principles, “Improvements to Not-for-Profit Standards,” as well as input from the AcSB’s Not-for-Profit Advisory Committee. 2 Since the issuance of the Statement of Principles, the AcSB carried out extensive consultations to reach its stakeholders, including several cross-county roundtable meetings as well as various private meetings with interested groups. The AcSB met independently and jointly with PSAB to discuss the responses received on the Statement of Principles. Since that time, the AcSB also developed its 2016-2021 Strategic Plan, which outlines the AcSB’s vision, how it intends to operate and the broad policy objectives that will guide its standard-setting activities. The strategies provide a basis for, and promote, stakeholder confidence in the information reported by publicly accountable enterprises, private enterprises, NFPOs and pension plans. As part of the strategic planning process relating to Part III of the Handbook, the AcSB has reaffirmed its commitment to continue to: (a) maintain a separate set of standards for private sector NFPOs that addresses transactions and circumstances unique to such organizations; (b) review the standards in Part III and update the standards as necessary; and (c) work with PSAB, with the objective of achieving consistency between private and public sector standards for NFPOs when appropriate. 3 In response to the feedback from private sector stakeholders to the April 2013 AcSB/PSAB Joint Statement of Principles, “Improvements to Not-for-Profit Standards,” and as part of its commitment to improve the standards in Part III, the AcSB has divided the principles among three projects: (a) accounting standards improvements; (b) reporting controlled and related entities by NFPOs; (c) contributions – revenue recognition and related matters. 4 To assist the AcSB in achieving its mandate, the AcSB established a new permanent committee for NFPOs. The Not-for-Profit Advisory Committee provides expertise and input to the AcSB on issues relating to accounting standards for private sector NFPOs, including the proposals in this Exposure Draft. The Advisory 18 | Basis for Conclusions – February 2017 Committee includes auditors, preparers and users of financial statements, including grantors, with a range of backgrounds and experience from across Canada. Members include representatives from organizations of differing sizes and in a variety of industries; some organizations provide benefit to individuals and society and others serve the public. 5 The AcSB has also considered the consequences of applying these proposals relative to the objective of financial statements and the benefit versus cost constraint. As described in FINANCIAL STATEMENT CONCEPTS FOR NOT-FORPROFIT ORGANIZATIONS, Section 1001, the purpose of financial reporting is to “communicate information that is useful to members, contributors, creditors and other users in making their resource allocation decisions and/or assessing management stewardship.” Also as described in Section 1001, the AcSB considers the benefit versus cost constraint, which states: “In developing accounting standards, the Board weighs the anticipated costs and benefits of its proposals in general terms to assess whether they are justified on cost/benefit grounds.” EFFECTS ANALYSIS 6 The AcSB is committed to updating accounting standards for not-for-profit organizations, as necessary, to ensure these standards continue to meet the needs of users of private sector NFPO financial statements. Part of this process is to understand the differing needs of these users. Based on that understanding, the AcSB decides, on a case-by-case basis, the extent to which a standard that is being improved should align with or differ from the corresponding public sector NFPO standard (issued in the CPA Canada Public Sector Accounting (PSA) Handbook). Paragraphs 7-15 highlight the effects of the proposed amendments. Tangible capital assets and intangible assets 7 The AcSB recognizes that, since NFPOs with revenues less than $500,000 are permitted to limit the application of TANGIBLE CAPITAL ASSETS HELD BY NOT-FORPROFIT ORGANIZATIONS, Section 4431, and INTANGIBLE ASSETS HELD BY NOTFOR-PROFIT ORGANIZATIONS, Section 4432, the effects of the proposals would be minimal for smaller organizations. However, the AcSB notes that in the future it will be re-examining this exemption. 8 A primary effect of the proposals is to improve comparability in financial reporting by eliminating redundancies between Parts II and III of the Handbook by removing duplicative guidance for tangible capital assets and intangible assets in Part III. During its strategic plan consultations, the AcSB was informed by stakeholders that having common guidance in Parts II and III that results in common reporting improves understandability of the information, especially for those stakeholders who deal with both Parts II and III. Also, the proposals to require the recognition of partial impairments of tangible capital assets and intangible assets, as well as the proposals to separate a tangible capital asset into its component parts, would result Accounting Standards Improvements for Not-for-Profit Organizations | 19 in improved comparability in financial reporting between NFPOs in the private sector, NFPOs in other jurisdictions and other private sector enterprises. The proposals would also provide more timely and useful information for users of NFPO financial statements. In particular, componentization would result in users being alerted sooner to potential maintenance issues (for example, a roof that needs to be replaced). The AcSB also recognizes the costs to preparers and auditors of assessing and calculating partial impairments and applying the guidance related to componentization, including the costs of getting this information audited. However, the AcSB received feedback that partial impairments would be infrequent and would usually result from redundancies or damage to assets. The AcSB was also informed by the Advisory Committee that the need to componentize would be rare or possibly not material. The AcSB notes that componentization is an existing requirement for private enterprises in Part II of the Handbook and was carried forward from the prechangeover standards in Part V of the Handbook. 9 As a result of applying the proposals in Section 4433, the requirements for the capitalization, amortization, write-down and disposal of tangible capital assets for NFPOs would not differ substantially between NFPOs in the private sector and NFPOs in the public sector that do not use Sections PS 4200 to PS 4270 (the PS 4200 series) in the PSA Handbook. However, for the proposals related to intangible assets in Section 4434, there would continue to be a lack of comparability between NFPOs in the private sector and NFPOs in the public sector that do not use the PS 4200 series until PSAB considers whether it should address the accounting for intangible assets. Currently, intangible assets are not generally recognized as assets in the public sector. 10 Additionally, until such time as the PSAB addresses the PS 4200 series in the PSA Handbook, the proposals to recognize partial impairments for tangible and intangible assets and the proposals related to componentization of tangible assets would create a difference between NFPOs in the private sector and those NFPOs in the public sector that do follow the PS 4200 series. Works of art, historical treasures and similar items not part of a collection 11 The proposals retain the current requirements for works of art, historical treasures and similar items not part of a collection. However, the proposals in Sections 4433 and 4434 to recognize partial impairments of tangible capital assets and intangible assets means that works of art, historical treasures and similar items that are not part of a collection would be written down to reflect partial impairments. In addition, works of art, historical treasures and similar items that are not part of a collection and are amortized would be subject to the requirements for componentization. The AcSB recognizes the additional costs to preparers and auditors of applying the guidance related to componentization, and assessing and calculating partial impairments, including the costs of getting this information audited. However, the 20 | Basis for Conclusions – February 2017 AcSB received feedback that componentization and partial impairments would be infrequent. 12 There would continue to be a lack of comparability between NFPOs in the private sector and NFPOs in the public sector that do not use the PS 4200 series in the PSA Handbook until the PSAB considers whether it should address the accounting for works of art, historical treasures and similar items not part of a collection by all public sector entities. Currently, these types of assets are not recognized in the public sector for those NFPOs following the PSA Handbook without the PS 4200 series. There would also be a lack of comparability created between NFPOs in the private sector and NFPOs in the public sector that do follow the PSA Handbook with the PS 4200 series in regard to the proposals to componentize and recognize partial impairments of works of art and historical treasures not part of a collection. Collections 13 The AcSB has been informed by stakeholders that there is diversity in practice in the accounting for collections by NFPOs. Some collections are not recorded, and others are recorded at nominal value, cost or on another basis. A primary effect of the proposal to require collections be recorded at cost or nominal value would be to reduce this diversity. The AcSB was informed by stakeholders and the Advisory Committee that this proposal would also increase consistency in the recognition of collections since NFPOs would, at a minimum, need to record their collections at nominal value. Consistency benefits users of NFPO financial statements because when economically similar items are accounted for the same way by various NFPOs, it makes the financial statements of different NFPOs more comparable. While NFPOs can currently choose to recognize collections on their statements of financial position, the AcSB has been informed that many NFPOs do not record them. Therefore, recognizing collections on the face of the statement of financial position would also bring increased awareness to the existence of collections held by NFPOs. 14 The AcSB recognizes the costs to preparers of assessing and calculating partial impairments of collections and the costs associated with getting this information audited. However, the AcSB received feedback that partial impairments would be rare and would usually result from a significant event such as a fire or flood. 15 There would continue to be a lack of comparability between NFPOs in the private sector and NFPOs in the public sector that do not use the PS 4200 series in the PSA Handbook until PSAB consider collections more broadly. The PSA Handbook without the PS 4200 series does not refer to collections, only works of art and historical treasures. For those NFPOs that follow the PSA Handbook without the PS 4200 series, works of art and historical treasures (whether or not part of a collection) are not recognized in the financial statements because a reasonable estimate of the future benefits associated with such property cannot be made. Accounting Standards Improvements for Not-for-Profit Organizations | 21 Instead, the existence of such property is disclosed. Additionally, until such time as PSAB addresses the PS 4200 series, requiring the capitalization of collections at cost or nominal value may create a difference between NFPOs in the private sector and those NFPOs in the public sector that do follow the PS 4200 series. COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section PS 4240 in the PSA Handbook only requires NFPOs to disclose their collections, although they are not precluded from capitalizing them. Conclusion on effects analysis 16 Having considered the effects of the proposals in Sections 4433 and 4434, as well as COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4441, as discussed above, the AcSB thinks that the proposals would result in significant improvements to financial reporting for assets held by NFPOs. TANGIBLE CAPITAL ASSETS AND INTANGIBLE ASSETS Removing redundancies between Parts II and III of the Handbook 17 Part III of the Handbook is applicable only to private sector NFPOs. NFPOs applying Part III also apply the standards in Part II of the Handbook to the extent that the Part II standards address topics not addressed in Part III. 18 The standards in Part II of the Handbook have been developed with the needs of the financial statement users in mind. The AcSB thinks that financial reporting would be improved if standards in the 4400 series did not simply reproduce, interpret or explain standards otherwise contained in Part II. The AcSB continues to support directing NFPOs to the same financial reporting standards followed by private enterprises when those standards apply to circumstances and transactions that are common to all entities in the private sector. Such an approach has resulted in more consistent financial statement reporting within the private sector, as well as those financial statements being more readily understood by users. 19 Currently, the accounting requirements in Part III of the Handbook regarding the capitalization, amortization, and disposal of tangible capital assets are either identical, or substantially similar, to the standards in Part II of the Handbook. TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4431, corresponds closely to PROPERTY, PLANT AND EQUIPMENT, Section 3061 in Part II. Therefore, the AcSB proposes to remove the redundancies between Parts II and III by not including guidance in Section 4433 that is duplicative to Section 3061 in Part II. The AcSB notes that any guidance in TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4431, or INTANGIBLE ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4432, that is unique to Part III (for example, material related to contributed assets) would be included in Sections 4433 and 4434. The AcSB also proposes to add guidance to Section 4433 to clarify what is included in the cost of a contributed tangible capital asset. 22 | Basis for Conclusions – February 2017 Amortization of tangible capital assets 20 The AcSB proposes that amortization guidance be excluded from Section 4433 and, consequently, NFPOs would apply PROPERTY, PLANT AND EQUIPMENT, Section 3061 in Part II, for guidance on amortizing all tangible capital assets, including contributed capital assets. However, the guidance for calculating amortization of tangible capital assets differs between TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4431, and Section 3061 in Part II. Paragraph 4431.16 indicates amortization of capital assets is based on “cost less residual value” and is provided over the asset's estimated “useful life” in a rational and systematic manner. 21 Alternatively, PROPERTY, PLANT AND EQUIPMENT, paragraph 3061.16 in Part II, states that amortization of capital assets is the greater of cost less residual value over the asset's estimated useful life and cost less salvage value over the life of the asset. Therefore, excluding the current amortization guidance in TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4431, from Section 4433 means that NFPOs would apply paragraph 3061.16 in Part II, instead, which may differ from current practice. 22 The AcSB was informed by the Advisory Committee that they did not foresee any issues with the amortization requirements in PROPERTY, PLANT AND EQUIPMENT, Section 3061 in Part II, because salvage values are likely nominal or less than residual value and, therefore, would not likely result in a change in practice. Consequently, the AcSB proposes to exclude amortization guidance from Section 4433. Componentization 23 The AcSB recognizes that by proposing to direct NFPOs to follow PROPERTY, PLANT AND EQUIPMENT, Section 3061 in Part II, NFPOs would need to consider the guidance related to componentization, which is not included in TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4431. Paragraph 3061.18 in Part II states: "The cost of an item of property, plant and equipment made up of significant separable component parts is allocated to the component parts when practicable and when estimates can be made of the lives of the separate components." The AcSB notes that componentization was also a requirement under the pre-changeover standards in Part V of the Handbook. Therefore, requiring NFPOs to consider componentization aligns with the existing requirements for private enterprises in Part II. The AcSB could not identify any unique characteristics or reasons why NFPOs should be different from other entities and not be required to consider componentization. 24 The AcSB notes that the requirements for componentization could affect many NFPOs. For example, NFPOs may have to separate a furnace from a building. The AcSB acknowledges that some additional work by preparers and auditors may be Accounting Standards Improvements for Not-for-Profit Organizations | 23 required to apply the guidance for componentization. However, the Advisory Committee noted that some NFPOs already have the information to do componentization and, in fact, a few already do it. Some members of the Advisory Committee reflected on how capital maintenance of NFPO assets could be important to some NFPOs and their users and, therefore, componentization could be useful. For example, the roof of a building or a furnace that needs to be replaced has a much shorter useful life than the entire building. Showing a roof or a furnace separately from the building could highlight a potentially significant maintenance issue. 25 After discussion, the Advisory Committee noted that NFPOs have the same characteristics as other entities when accounting for components of tangible capital assets. Accordingly, the AcSB proposes that NFPOs apply the guidance for componentization in PROPERTY, PLANT AND EQUIPMENT, Section 3061 in Part II. Recognizing partial impairments of tangible capital assets and intangible assets 26 Currently, TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4431, and INTANGIBLE ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4432, only require write-offs of tangible capital assets and intangible assets when the assets are fully impaired. PROPERTY, PLANT AND EQUIPMENT, Section 3061 in Part II, does not address impairment. Section 3061 and GOODWILL AND INTANGIBLE ASSETS, Section 3064 in Part II, require that tangible capital assets and intangible assets be tested for impairment in accordance with IMPAIRMENT OF LONG-LIVED ASSETS, Section 3063 in Part II. Section 3063 in Part II requires that an impairment loss "be recognized when the carrying amount of a long-lived asset is not recoverable and exceeds its fair value." Therefore, in Part II, partial impairments are recognized when a tangible capital asset’s and intangible asset's carrying amount is not recoverable and exceeds its fair value. 27 The AcSB notes that recognizing partial impairments is common among all types of entities and did not identify any unique circumstances for NFPOs that warrant different accounting. The Advisory Committee advised the AcSB that partial impairments for NFPOs would likely be infrequent as they generally would apply to buildings and usually result from redundancies or damage. For example, an impairment of an asset may have occurred when 25 percent of a building is no longer being used by the NFPO. The majority of respondents to the Statement of Principles agreed with recognizing partial impairments of tangible capital assets and intangible assets. These respondents also agreed that although an asset may no longer be working at its full potential, it still has value to the organization. Consequently, the AcSB proposes that NFPOs should recognize partial declines in their tangible capital asset’s and intangible asset's values. 24 | Basis for Conclusions – February 2017 28 One option the AcSB considered for recognizing write-downs of tangible capital assets and intangible assets would be to direct NFPOs to Part II. IMPAIRMENT OF LONG-LIVED ASSETS, paragraph 3063.04 in Part II, states: “An impairment loss shall be recognized when the carrying amount of a long-lived asset is not recoverable and exceeds its fair value.” However, the Advisory Committee expressed concerns to the AcSB that in Section 3063 recoverability of the carrying amount of an asset relates to future cash flows expected to result from the asset's use and disposal. Paragraph 3063.05 in Part II states: “The carrying amount of a long-lived asset is not recoverable if the carrying amount exceeds the sum of the undiscounted cash flows expected to result from its use and eventual disposition.” 29 The Advisory Committee informed the AcSB that NFPOs likely hold tangible capital assets and intangible assets whose future economic benefits or service potential are not directly related to their ability to generate cash flows. Instead, the future economic benefits or service potential is based on the amount the organization would need to pay to acquire the economic benefits or service potential to achieve its objectives and not on recoverability of expected future cash flows. Therefore, the Advisory Committee noted that because of these unique attributes, NFPOs should not be directed to Part II of the Handbook for impairments. Consequently, the AcSB proposes that guidance be added to Sections 4433 and 4434 for recognizing writedowns of tangible capital assets and intangible assets, instead of directing NFPOs to Part II. Indicators of impairment 30 IMPAIRMENT OF LONG-LIVED ASSETS, Section 3063 in Part II, includes a list of conditions that may indicate that a write-down of tangible capital assets and intangible assets is appropriate. The AcSB considered the need to add similar guidance to Sections 4433 and 4434. The Advisory Committee suggested that a decrease in service potential should also be added to the list of indicators since that would be a common example for NFPOs as to when a write-down of an asset may be necessary. Based on the Advisory Committee’s input, the AcSB proposes to add a list similar to Section 3063 in Part II to Sections 4433 and 4434 to indicate when a write-down of tangible capital assets and intangible assets may be appropriate. 31 The AcSB notes that the list of indicators is only meant to provide examples of conditions that may be present to indicate impairment; it is not meant to be a list of requirements for impairment. The AcSB also discussed whether the list of indicators should be segregated into different types (for example, primary versus secondary indicators or external factor versus internal factor indicators). However, the AcSB did not want to add unnecessary complexity for NFPOs and, therefore, did not segregate the list of indicators in Sections 4433 and 4434. Accounting Standards Improvements for Not-for-Profit Organizations | 25 Works of art, historical treasures and similar items not part of a collection 32 Occasionally, an NFPO may acquire works of art, historical treasures and similar items to be used as tangible capital assets or for sale. For example, the organization may acquire a work of art to be used as an office furnishing or receive a work of art that will be sold. Currently, COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, paragraph 4440.02, states: "Works of art, historical treasures and similar items that are not part of a collection are dealt with in TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4431, and INTANGIBLE ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4432." 33 The AcSB notes that at the time COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4440, was developed, INVENTORIES HELD BY NOT-FORPROFIT ORGANIZATIONS, Section 3032, did not exist. Therefore, for completeness, the Statement of Principles proposed to add a reference to Section 3032 in paragraph 4440.02. The proposal was to allow works of art, historical treasures and similar items to be accounted for according to their intended use (i.e., as capital assets or inventory items). Respondents agreed with the proposal and did not express any concerns. 34 However, the Advisory Committee expressed concerns to the AcSB with adding a reference to INVENTORIES HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 3032, since it may signal a change in practice, which is not the intent of the proposal. The AcSB notes that paragraph 4441.02 is not a requirement. Instead, the paragraph identifies guidance that may be applicable to works of art, historical treasures etc. not part of a collection. The Advisory Committee informed the AcSB they are not aware of any NFPOs that account for works of art etc. as inventories. Instead, they are either tangible capital assets, intangible assets or investments, so TANGIBLE CAPITAL ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4431, INTANGIBLE ASSETS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4432, or INVESTMENTS, Section 3051 in Part II are applied. The AcSB recognizes this is the case, although rare works of art etc. could be inventories. For example, an NFPO that is an art gallery could sell works of art to support a specific cause. Therefore, for completeness the AcSB proposes that these items continue to be accounted for as tangible capital assets, intangible assets, investments or as inventory type items depending on their intended use (i.e., in accordance with Sections 3032, 3051, 4433 or 4434). 35 The AcSB notes that the guidance in TANGIBLE CAPITAL ASSETS HELD BY NOTFOR-PROFIT ORGANIZATIONS, Section 4431, relating to land not being amortized would be excluded from Section 4433 because it is duplicative to the guidance in PROPERTY, PLANT AND EQUIPMENT, Section 3061 in Part II. The AcSB also notes that the proposals in Sections 4433 and 4434 to recognize partial impairments of tangible capital assets and intangible assets means that works of art, historical 26 | Basis for Conclusions – February 2017 treasures and similar items that are not part of a collection would be written down to reflect partial impairments. Measuring partial impairments of tangible capital assets and intangible assets 36 The AcSB and the Advisory Committee assessed various options for measuring the impairment of tangible capital assets and intangible assets such as writing an asset down to its fair value, value, or replacement cost. The AcSB recognizes that NFPOs have experience determining fair value (for example, contributed capital assets are initially measured at fair value). However, the Advisory Committee informed the AcSB that determining fair value would be difficult and, in some cases impracticable for many NFPOs. For many assets, NFPOs do not intend to sell them and some assets do not have readily available market values. The Advisory Committee also noted that determining fair value would be costly since an appraisal would be needed and auditors would need to verify the amount. Therefore, the Advisory Committee thought that the costs of determining fair value would exceed the benefits. Consequently, the AcSB recognizes the importance of giving NFPOs an alternative if fair value was required, particularly for situations when determining fair value would be too costly or when there are no readily available market prices for the asset. 37 The AcSB also considered whether, like the PSA Handbook, an asset should be written down to its “value” instead. That approach would allow an NFPO to choose the value that is the most appropriate and useful to its users (for example, fair value, future economic benefits or service potential). However, the AcSB was concerned that using ‘value’ is too vague and would result in diversity in practice. 38 The AcSB also considered writing an asset down from its net carrying amount to its replacement cost since NFPOs are familiar with using replacement cost (for example, inventories are measured at the lower of cost and current replacement cost). The AcSB thinks that a choice of replacement cost and fair value would be the most appropriate because it would provide clear parameters on the value to which an asset should be written down and also provide NFPOs the flexibility to choose the value that is readily available and at a lower cost. Therefore, the AcSB proposes that an asset should be written down to its replacement cost or fair value. Presentation and disclosure 39 The Advisory Committee discussed the disclosure requirements in IMPAIRMENT OF LONG-LIVED ASSETS, Section 3063 in Part II, relating to impairment and informed the AcSB they thought those disclosures would be useful to users of NFPO financial statements. Consequently, the AcSB proposes that Sections 4433 and 4434 direct NFPOs to follow the disclosure requirements in Section 3063 in Part II for impairments of tangible capital assets and intangible assets. The AcSB also proposes that a disclosure requirement be added to Sections 4433 and 4434 to Accounting Standards Improvements for Not-for-Profit Organizations | 27 describe whether the impairment is measured at the asset’s replacement cost or at fair value. Transition 40 The AcSB discussed that in the absence of specific transitional provisions, ACCOUNTING CHANGES, Section 1506 in Part II, requires amendments to be applied retrospectively, except if it is impracticable. The Advisory Committee informed the AcSB that retrospectively calculating partial impairments for all tangible capital assets and intangible assets of an NFPO and retrospectively separating tangible capital assets from their component parts could, in many cases, be impracticable. Therefore, by using the impracticable exception, some members of the Advisory Committee thought that Section 1506 in Part II would permit prospective application. 41 The AcSB notes the challenges of using the impracticable exception in ACCOUNTING CHANGES, Section 1506 in Part II, since the term impracticable is not defined in the Handbook and, consequently the understanding of impracticable varies in practice. The AcSB thinks that retrospectively separating tangible capital assets from their component parts could be onerous and subjective. The AcSB also thinks that calculating partial impairments retrospectively could be both difficult and require the use of hindsight. Therefore, the AcSB proposes that Sections 4433 and 4434 be applied prospectively. 42 The AcSB also recognizes that since componentization of tangible capital assets can provide useful information, as discussed in paragraph 24, some NFPOs may want to apply the requirements in PROPERTY, PLANT AND EQUIPMENT, Section 3061 in Part II, retrospectively. However, the AcSB considered the challenges in determining the amounts to allocate to the component parts. Therefore, the AcSB proposes to permit NFPOs on initial application of Section 4433 to allocate the costs of tangible capital assets to their component parts based on their cost or fair value at the date of acquisition; or their fair value or replacement cost at the date of application of Section 4433. 43 The AcSB also recognizes that some NFPOs may have the information to calculate the partial impairments of their assets, and these NFPOs may want to reflect the cumulative amount of these impairments at the date Sections 4433 and 4434 are first applied. Consequently, the AcSB proposes transitional provisions that permit an NFPO on initial application of Sections 4433 and 4434 to reflect, as a cumulative adjustment to opening net assets, all partial impairments existing at that date. This prevents an NFPO from having to recognize in its statement of operations in the current period partial impairments that occurred prior to the date of applying Sections 4433 and 4434. 28 | Basis for Conclusions – February 2017 44 The AcSB also proposes that an NFPO can only apply the transition provisions as described above to its annual financial statements relating to the first fiscal year in which Sections 4433 and 4434 are effective. COLLECTIONS Nature of collections 45 Collections can include a vast array of items such as paintings, writings, sculptures, artifacts, specimens, land and buildings. COLLECTIONS HELD BY NOT-FOR PROFIT ORGANIZATIONS, paragraph 4440.04, notes that although items meeting the definition of a collection exhibit the characteristic of assets, set out in FINANCIAL STATEMENT CONCEPTS FOR NOT-FOR-PROFIT ORGANIZATIONS, Section 1001, they are not considered capital assets because of their nature. An organization must protect and preserve the collection in perpetuity and any proceeds from the sale of collection items must be used to acquire additional items or for the direct care of the remaining collection. Historically, it is the existence of these unique attributes that has distinguished collections from capital assets and resulted in unique accounting requirements for collections. One could argue that the organization is simply a custodian of the collection items in order to protect and preserve them for public exhibition, education or research. 46 The AcSB and the Advisory Committee are aware that in some jurisdictions 1 works of art, historical treasures and other items that are part of a collection are called heritage assets and are accounted for the same as other assets.2 However, they are also aware that in the United States (US) there are specific requirements for items that meet the definition of a collection.3 In the US, NFPOs are encouraged to capitalize their collections. However, if collections are not capitalized, there are additional disclosure requirements. Therefore, consistent with the US, the AcSB and the Advisory Committee thinks that collections should be accounted for based on their unique nature. The AcSB notes that when items do not or no longer meet the definition of a collection, they should be accounted for in accordance with INVENTORIES, Section 3032, INVESTMENTS, Section 3051 in Part II, Section 4433 or Section 4434. If an NFPO does not have, or no longer has, an organizational policy that requires any proceeds from the sale of collection items to be used to acquire additional items or for the direct care of the remaining collection, COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4441, would not apply. 1 Such as Australia, New Zealand and the United Kingdom. 2 Except when the value of an item cannot be reliably measured or too costly, in which case, only disclosure is required. 3 The definition of a collection in the US is consistent with Canada. Accounting Standards Improvements for Not-for-Profit Organizations | 29 Initial recognition and measurement 47 Currently, COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4440, is a disclosure standard and consequently does not address the recognition of collections held by NFPOs. As a result, practice with respect to recognition and measurement of collections held by NFPOs varies. Some collections are not recorded, and some are recorded at nominal value, cost or other basis. Therefore, the objective of the proposals is to require collections be recorded at cost or nominal value to bring more consistency and comparability to the reporting of collections. Also, requiring an NFPO to, at a minimum, recognize its collections at nominal value in the statement of financial position is meant to highlight the existence of the collection. Currently, it may only be evident in the financial statement notes. 48 As part of developing these proposals, the AcSB consulted various stakeholders who hold different types of collections (for example, art galleries, museums and universities). The AcSB was informed by stakeholders, as well as the Advisory Committee, that the historical cost of a collection is not necessarily reflective of the current market value of or the benefits to be received from, a collection. Similarly, any attempt to ascertain current market values for many collections, comprising thousands of unique items, may be impracticable or the costs would exceed the benefits of doing so. However, there are other cases when the fair value is known (for example, when donation receipts are issued or when the item is purchased). Therefore, the AcSB agreed that if collections are required to be recognized, an accounting policy choice with an alternative to cost would be needed. Providing this choice would allow NFPOs to take cost/benefit considerations into account, while still providing useful information to users by highlighting the existence of the collection on the face of the statement of financial position. 49 The AcSB discussed various options to highlight the existence of collections to users. One option would be note disclosure. However, the AcSB notes that there are many situations when the existence of a collection would not be readily apparent (for example, at a hospital or a university). In its outreach with stakeholders, users emphasized to the AcSB the importance of highlighting the existence of the collection on the face of the statement of financial position, rather than disclosure in the notes. The Advisory Committee suggested another option of including a note reference on the statement of financial position similar to a leases commitments note (i.e., Note X Collections). A note reference on the statement of financial position would still highlight the existence of the collection but would not put an arbitrary nominal value in the financial statements. However, the AcSB was informed by the stakeholders it consulted that putting a note reference on the statement of financial position may send a message that the collection has no value, which is not the case; the value is simply unknown. 30 | Basis for Conclusions – February 2017 50 The final option discussed was recognizing collections at nominal value to provide an alternative to measuring collections at cost. This option would give a collection as much prominence on the statement of financial position as other assets and would accommodate situations when the value of a collection is unknown or difficult to value. Although recognizing a nominal value may seem immaterial to some NFPOs, the AcSB notes that the importance of a collection to an NFPO may have qualitative as well as quantitative considerations that must be taken into account when considering materiality. For example, recognizing collections would highlight to users of an NFPO’s financial statements assets that are key to carrying out and achieving its objectives. Consequently, the AcSB thinks that using nominal value as an alternative to cost is most appropriate and proposes that all collections be recorded at either cost or nominal value. 51 The AcSB also discussed whether the choice of recording the collection at cost or nominal value should be an accounting policy choice that would be applied to all of an NFPO’s collections, versus allowing a different policy choice for each collection. The Advisory Committee informed the AcSB that consistency within the financial statements of an NFPO in accounting for its collections is important and applying the same accounting policy choice to all of an NFPO’s collections would provide more useful information to users. However, the Advisory Committee also cautioned the AcSB that requiring the same policy choice to be applied for all collections may deter NFPOs from using cost. For example, if an NFPO has two collections (i.e., one that is recorded at cost and the other one that is not recorded because it is too onerous to determine the cost), the NFPO would likely choose to record both collections at nominal value. This choice could prevent the NFPO from continuing to record one collection at cost. 52 Based on input from some stakeholders and the Advisory Committee, the AcSB is not aware of situations when an NFPO has multiple collections that are valued differently. For most NFPOs, all items are considered part of one collection or they choose the same policy for all of their collections. Therefore, the AcSB proposes that the requirement to record collections at either cost or nominal value should be an accounting policy choice that is applied by an NFPO to all of its collections. The AcSB notes that in accordance with ACCOUNTING CHANGES, Section 1506 in Part II, an NFPO may change its accounting policy for collections. The AcSB is seeking input on whether the proposals would result in NFPOs reporting multiple collections and whether NFPOs with multiple collections should be permitted to value each collection differently. 53 The AcSB also recognizes that COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4440, does not rely on Part II of the Handbook and the guidance for determining cost is proposed to be excluded from Section 4433 as part of the tangible capital asset proposals. The Advisory Committee informed the AcSB that guidance for determining cost, including a description of what is included in the Accounting Standards Improvements for Not-for-Profit Organizations | 31 cost of a collection, would be useful to NFPOs. Therefore, the AcSB proposes to specify in Section 4441 that the cost of a collection in addition to the purchase price of acquired items or the fair value of contributed items, also includes all other costs directly attributable to acquiring the items in the collection (for example, installation costs and transportation costs). The AcSB also proposes to clarify that the cost incurred in protecting and preserving the items in a collection is a repair or maintenance activity and should be expensed. 54 In addition, consistent with the guidance included in Section 4433, it is proposed that Section 4441 would specify that if an item is purchased by an NFPO at substantially below fair value, the item would be recognized at its fair value, with the difference between the consideration paid and the fair value reported as a contribution. Amortization 55 In Parts II and III of the Handbook, for assets with limited lives subsequent to initial recognition, an organization must amortize its assets over their useful life, which is defined as the period over which an asset is expected to be used by an organization. However, for assets with unlimited lives, amortization is not required. Since the nature of collections requires an organization to protect and preserve these assets in perpetuity, the assets have an unlimited life and, therefore, amortization is not required. This treatment is consistent with how other types of assets are accounted for that have unlimited lives (for example, land and certain intangible assets). Therefore, the AcSB proposes that Section 4441 should specify that amortization is not required. Partial impairments of collections 56 The Advisory Committee informed the AcSB that they did not see a reason why collections would not be written down consistent with the proposals for tangible capital assets, intangible assets and works of art, historical treasures and similar items not part of a collection (i.e., so that the value of the assets are not overstated). Based on input from the Advisory Committee, the AcSB thinks that write-downs of collections would be rare (for example, when the write-downs are the result of a significant event, such as a fire or a flood, in which case the amount and timing of the impairment would be known). Consequently, for collections recorded at cost, the AcSB proposes that they be written down whenever events or changes in circumstances indicate that the net carrying amount of the collection exceeds its replacement cost or fair value. The AcSB also proposes that, consistent with the proposals for Sections 4433 and 4434, examples of conditions that may indicate that a write-down is appropriate would be added to Section 4441. 32 | Basis for Conclusions – February 2017 Disposals 57 The AcSB notes that in accordance with the definition of a collection in COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4440, an NFPO is required to use all proceeds from the sale of one or more items of a collection to purchase other items in the collection or care for existing items. Since Section 4440 did not contain guidance on accounting for disposal of collection items, the AcSB thinks that it would be helpful to include guidance that specifies how to account for the gains and losses on such disposals. Therefore, the AcSB proposes to add guidance to Section 4441, which requires the gain or loss on disposal of contributed collection items that have external restrictions to be accounted for in accordance with CONTRIBUTIONS — REVENUE RECOGNITION, Section 4410. However, for items in a collection that do not have external restrictions and are disposed of, the gain or loss is recognized in the statement of operations. 58 The AcSB notes that COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4440, contains additional disclosure requirements relating to proceeds from the sale of collection items that are useful and are proposed to be included in Section 4441. Paragraph 4441.14(e) states that an NFPO should disclose: “proceeds of any disposals of collection items in the period and how the proceeds were used.” The AcSB also notes that CASH FLOW STATEMENT, Section 1540 in Part II requires that an NFPO should disclose the amount of cash for which the use is restricted. Therefore, the application of paragraph 4441.14(e) and Section 1540 in Part II would highlight that the proceeds from the sale of collection items are restricted. The AcSB notes this could be an internal restriction (i.e., the definition of a collection requires the sale proceeds be restricted) or an external restriction (i.e., a donor stipulation on a contributed collection item). The AcSB is seeking input on whether the requirements in Sections 4441 and 1540 adequately inform users when the proceeds on disposal of items in a collection are restricted (i.e., must be used to acquire more items or maintain the existing collection). The AcSB is also seeking input on how cash received on disposal of items in a collection prior to acquiring more items or maintaining the existing collection is reported (i.e., whether the cash is separately identified on the statement of financial position or disclosed in the notes). Presentation and disclosures 59 The Advisory Committee informed the AcSB that the current disclosure requirements in COLLECTIONS HELD BY NOT-FOR-PROFIT ORGANIZATIONS, Section 4440, are working well in practice. Consequently, the AcSB proposes to include the current disclosures from Section 4440 in Section 4441. In addition, the AcSB proposes to add a requirement that the amount recognized as a collection would be presented on a separate line in the statement of financial position. Presenting the collection on a separate line would achieve the objective of Accounting Standards Improvements for Not-for-Profit Organizations | 33 highlighting the existence of the collection to users. The AcSB also proposes that, consistent with IMPAIRMENT OF LONG-LIVED ASSETS, Section 3063 in Part II, disclosure requirements for the write-down of collections should also be added to Section 4441 since this information is also useful to users. Transition 60 The AcSB notes that in the absence of specific transitional provisions, ACCOUNTING CHANGES, Section 1506 in Part II, requires amendments to be applied retrospectively, except if it is impracticable. The AcSB thinks that retrospective application would be useful since it would provide comparable information with the prior year. However, the AcSB recognizes the challenges in retrospectively applying the proposals for those NFPOs that choose to record their collections at cost, particularly with measuring items in a collection that were acquired in previous periods. 61 The AcSB thinks it is important to make the transition to cost easier since recognizing collections at cost results in more useful information to financial statement users. Consequently, the AcSB proposes to provide relief that can only be used on transition to Section 4441 by NFPOs that choose to recognize their collections at cost. These NFPOs are permitted to capitalize retrospectively the items in a collection acquired in previous periods using either: cost or fair value at the date of acquisition; or fair value or replacement cost at the date of adoption of Section 4441. The AcSB is also aware there could be situations when the cost of one or more items in a collection cannot be reasonably determined and, therefore, proposes that those items be recorded at nominal value. In these situations, the AcSB notes that recording an item at nominal value does not preclude the remaining items in the collection from being recorded at cost. 62 Consistent with the proposals for tangible capital assets and intangible assets, the AcSB recognizes that some NFPOs would have the information to determine the partial impairments of their collections and may want to reflect the cumulative amount of these impairments at the date of application of Section 4441. Consequently, on initial application of Section 4441, the AcSB proposes to permit an NFPO to reflect, as a cumulative adjustment to opening net assets, all partial impairments existing at that date. This prevents an NFPO from having to recognize in its statement of operations in the current year, partial impairments that occurred prior to the date of application of Section 4441. 63 Consistent with the proposals for tangible capital assets and intangible assets, the AcSB proposes that an NFPO can only apply the transitional provisions as described above to its annual financial statements relating to the first fiscal year in which Section 4441 is effective. 34 | Basis for Conclusions – February 2017 EFFECTIVE DATE 64 Selecting an effective date for amendments is an important step in the AcSB's due process. Taking into account the proposed transitional provisions, the AcSB thinks that the proposed effective date (fiscal years beginning on or after January 1, 2019), will provide NFPOs sufficient time to implement the proposals. 65 The AcSB is seeking input on whether an effective date of April 1st for these and future proposals would be preferable given that many NFPOs have March 31st fiscal year ends. The AcSB notes that for those NFPOs that have March 31 fiscal year ends, using January 1, 2019 or April 1, 2019 as the effective date has the same result (i.e., March 31, 2020 would be the first fiscal year end to which the proposals would apply). However, for those NFPOs with December 31 year ends, a January 1, 2019 or April 1, 2019 effective date makes a difference. In that circumstance, a January 1, 2019 effective date would mean December 31, 2019 would be the first fiscal year end to which the proposals would apply. However, an April 1, 2019 effective date would result in December 31, 2020 as the first fiscal year end to which the proposals would apply. Accounting Standards Improvements for Not-for-Profit Organizations | 35 © 2017 Chartered Professional Accountants of Canada Excerpts from and/or links to this publication may be used, provided that full and clear credit is given to the appropriate Financial Reporting & Assurance Standards Canada board, oversight council, committee or individual author, with appropriate and specific direction to the original content. For assistance with crediting this publication, please contact [email protected].
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