Since its issuance in June of 2016, much discussion has been had regarding Accounting Standards Update (ASU) 2016-13, Financial Instruments – Credit Losses (ASC 326): Measurement of Credit Losses on Financial Instruments. This new standard guides how an entity should measure credit losses on financial instruments, with most of the conversation focused on the impact on financial institutions.
Given the emphasis on financial assets, including loans and certain debt securities, many in the industry are looking to familiarize themselves with it before it takes effect in 2023.
The guidance in ASC 326 applies to the following:
- Financial assets measured at amortized cost, including:
- Financing Receivables
- Held-to-maturity debt securities
- Receivables that result from revenue transactions within the scope of Topic 605 on revenue recognition, Topic 606 on revenue from contracts with customers, and Topic 610 on other income
- Receivables that relate to repurchase agreements and securities lending agreements within the scope of Topic 860
- Net investments in leases recognized by a lessor in accordance with Topic 842 on leases
- Off-balance-sheet credit exposures not accounted for as insurance
- Reinsurance recoverables that result from insurance transactions within the scope of Topic 944 on insurance
ASC 326 defines financial assets as cash, evidence of ownership interest in an entity, or a contract that conveys one entity a right to do either of the following:
- Received cash or another financial instrument from a second entity
- Exchange other financial instruments on potentially favorable terms with the second entity
Based on the aforementioned, trade receivables represent a financial asset that would fall within the scope of ASC 326. Given that CECL applies to trade receivables, estimated lifetime credit losses will need to be recorded at inception, based on historical information, current conditions, and reasonable and supportable forecasts.
While the probability criterion for initial receivable recognition under ASC 606 considers a customer’s ability and intent to repay, likely repayment under ASC 606 does not imply a credit risk-free receivable or remove the requirement to comply with CECL. Concepts such as pooling receivables with common risk characteristics and employing a methodology for calculating estimated credit losses consistent with the guidance in ASU 326 are required with CECL.
Complying with ASC 326 has been challenging for the public companies that adopted CECL in 2020 and will be equally challenging for the private companies set to adopt it in 2023.
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