Pandemic spurs changes to effective dates
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Pandemic spurs changes to effective dates

10 months ago · 4 min read

As the coronavirus pandemic gripped the world and caused disruption for businesses and organizations of all sizes, numerous standard setters and regulators acted to amend or delay effective dates to give stressed company managers and CPA firm leaders the opportunity to respond to the crisis without having to worry about implementing new standards or rules.

“Health and safety continue to be our first priority,” SEC Chairman Jay Clayton said in late March.

Here is a list that pulls together some of the most notable effective dates that have been delayed.

AICPA Auditing Standards Board

The effective dates of SASs 134–140 have been deferred for one year. SAS No. 141 defers the effective date to Dec. 15, 2021, for the following SASs:

  • SAS No. 134, Auditor Reporting and Amendments, Including Amendments Addressing Disclosures in the Audit of Financial Statements, as amended by SASs No. 137, 138, and 140.

  • SAS No. 135, Omnibus Statement on Auditing Standards — 2019.

  • SAS No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, as amended by SASs No. 138 and 140.

  • SAS No. 137, The Auditor’s Responsibilities Relating to Other Information Included in Annual Reports.

  • SAS No. 138, Amendments to the Description of the Concept of Materiality.

  • SAS No. 139, Amendments to AU-C Sections 800, 805, and 810 to Incorporate Auditor Reporting Changes From SAS No. 134.

  • SAS No. 140, Amendments to AU-C Sections 725, 730, 930, 935, and 940 to Incorporate Auditor Reporting Changes From SAS Nos. 134 and 137.

SAS No. 141 lifts the prohibition against early implementation to enable those firms that choose to proceed sooner than the delayed effective date to do so.

When preparing to implement, it is important to recognize that this is not just adopting a new reporting model; various amendments to other AU-C sections may have performance implications for early in the audit. For example, SAS No. 134 amends AU-C Section 260, The Auditor’s Communication With Those Charged With Governance, to require the auditor to communicate significant risks identified by the auditor as part of the overview of the planned scope and timing of the audit communication.

The ASB recommends SASs No. 134–140 be implemented concurrently.

AICPA Peer Review Board

CPA firms have been granted six-month extensions for peer reviews, corrective actions, and implementation plans with original due dates between Jan. 1 and Sept. 30 of this year.

The Peer Review Board and the AICPA Peer Review Program staff will continue to monitor the pandemic through the summer months and will evaluate whether automatic extensions are appropriate for firms with due dates after Sept. 30, 2020.

Despite the extended due dates, firms are not required to wait an additional six months to go through with their peer reviews.

AICPA Professional Ethics Executive Committee

PEEC extended the effective dates of the following interpretations to the AICPA Code of Professional Conduct by one year:

  • The “Information Systems Services” interpretation (ET §1.295.145), which is now effective on Jan. 1, 2022, with early implementation permitted.

  • The “State and Local Government Client Affiliates” interpretation (ET §1.224.020), which is now effective for years beginning after Dec. 15, 2021.

  • The “Leases” interpretation (ET §1.260.040), which is now effective for fiscal years beginning after Dec. 15, 2020, with early implementation permitted.

FASB

FASB voted to extend by one year the effective date of its revenue recognition standard to all nonpublic entities that have not yet issued their financial statements.

The final Accounting Standards Update (ASU) is expected to give nonpublic entities the option of adopting the revenue recognition standard (FASB ASC Topic 606, Revenue From Contracts With Customers) on the current implementation date or deferring implementation for one year.

FASB also amended the effective date of its lease accounting standard for private companies and not-for-profits. Early adoption will be permitted. For private companies and private not-for-profits, the effective date will be for fiscal years beginning after Dec. 15, 2021, and interim periods within fiscal years beginning after Dec. 15, 2022.

FASB defines public not-for-profits as not-for-profits that have issued or are conduit obligors for securities that are traded, listed, or quoted on an exchange or an over-the-counter market. For public not-for-profits that have not yet issued financial statements or made them available for issuance, the effective date will be fiscal years beginning after Dec. 15, 2019, including interim periods within those fiscal years.

FASB instructed its staff to draft an ASU that describes the delay; the board members indicated that they will vote in favor of the ASU on the final, written ballot.

GASB

GASB extended the effective dates of numerous guidance by issuing GASB Statement No. 95, Postponement of the Effective Dates of Certain Authoritative Guidance.

The effective dates of GASB Statement No. 87, Leases, and Implementation Guide No. 2019-3, Leases, have been postponed by 18 months.

Effective dates are extended by one year for certain guidance in the following pronouncements:

  • Statement No. 83, Certain Asset Retirement Obligations.

  • Statement No. 84, Fiduciary Activities.

  • Statement No. 88, Certain Disclosures Related to Debt, Including Direct Borrowings and Direct Placements.

  • Statement No. 89, Accounting for Interest Cost Incurred Before the End of a Construction Period.

  • Statement No. 90, Majority Equity Interests.

  • Statement No. 91, Conduit Debt Obligations.

  • Statement No. 92, Omnibus 2020.

  • Statement No. 93, Replacement of Interbank Offered Rates.

  • Implementation Guide No. 2017-03, Accounting and Financial Reporting for Postemployment Benefits Other Than Pensions (and Certain Issues Related to OPEB Plan Reporting).

  • Implementation Guide No. 2018-1, Implementation Guidance Update — 2018.

  • Implementation Guide No. 2019-1, Implementation Guidance Update — 2019.

  • Implementation Guide No. 2019-2, Fiduciary Activities.

SEC

The SEC in late March gave public companies and certain investment funds and investment advisers disclosure relief related to the coronavirus.

Public companies were given a 45-day extension to file certain disclosure reports that otherwise would have been due between March 1 and July 1. A previous notice of relief issued March 4 covered the period from March 1 to April 30.

The SEC also issued orders that gave certain investment funds and investment advisers additional time with respect to holding in-person board meetings and meeting certain filing and delivery requirements.

This extended the filing period covered by the SEC’s original orders issued March 13.

Conditions for public companies to utilize the order include a current report of a summary of why the relief is needed in the particular circumstances for each periodic report that is delayed.

For investment funds and investment advisers, the conditions include notifying SEC staff and/or investors, as applicable, of the intent to rely on the relief. Investment funds and advisers generally no longer need to describe why they are relying on the order or estimate a date by which the required action will occur.

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