Case Study 4

Note Disclosures

Learning objectives

  • Identify “real world” applications of several common footnote disclosures.
  • Recognize the use of fair value, pledges receivable, and contributed services in the financial statements.

Discussion

The term disclosure includes everything in the financial statements. Statement captions, titles, and classifications are all disclosures. In addition, financial statements are not complete without note disclosures. (The auditor’s report covers all disclosures, including those in the notes to the financial statements.) Some elements of disclosure may be either embodied in the principal statements or presented in notes—depending on convenience of space.

Why is disclosure important? Generally accepted accounting principles (GAAP) require adequate disclosure. Auditors evaluate disclosures before issuing their opinions on the financial statements. Although the need to provide additional disclosures in notes regarding a particular line in the statements may sometimes require judgment, most required disclosures have been promulgated in Sections 45 and 50 of each topic in the FASB Accounting Standards Codification® (ASC). A “Significant Accounting Policies” note is used for the purpose of disclosing specific accounting principles and the methods of applying those principles that are judged by management to be most appropriate to present fairly financial position, cash flows, and results of operations.

FASB Accounting Standards Update (ASU) 2018-13, Disclosure Framework — Changes to the Disclosure Requirements for Fair Value Measurement, was issued in August 2018. It removes the following disclosure requirements:

  • The amount of and reasons for transfers between Level 1 and Level 2 of the fair value hierarchy
  • The policy for timing of transfers between levels
  • The valuation processes for Level 3 fair value measurements
  • For nonpublic entities, the changes in unrealized gains and losses for the period included in earnings for recurring Level 3 fair value measurements held at the end of the reporting period

It also modifies current requirement by doing the following:

  • Allowing that in lieu of a rollforward for Level 3 fair value measurements, a nonpublic entity is required to disclose transfers into and out of Level 3 of the fair value hierarchy and purchases and issues of Level 3 assets and liabilities
  • Requiring for investments in certain entities that calculate net asset value to disclose the timing of liquidation of an investee’s assets and the date when restrictions from redemption might lapse only if the investee has communicated the timing to the entity or announced the timing publicly
  • Clarifying that the measurement uncertainty disclosure is to communicate information about the uncertainty in measurement as of the reporting date

ASU No. 2018-13 is effective for fiscal years and interim periods within those fiscal years beginning after December 15, 2019. Early adoption is permitted.

Excerpts from the 2020 AICPA Audit and Accounting Guide Not-for-Profit Entities

Risks and Uncertainties

  1. 3.185 FASB ASC 275, Risks and Uncertainties, requires entities to include in their financial statements information about the following:
    • The nature of their operations
    • Use of estimates in the preparation of financial statements

    In addition, if specified disclosure criteria are met, it requires entities to include in their financial statements disclosures about the following:

    • Certain significant estimates
    • Current vulnerability due to certain concentrations

    FASB ASC 958-605-55-70 includes an example of a vulnerability of concentration of risk because of reliance on major donors. FASB ASC 275-10-55 includes other examples of disclosures that may be pertinent for NFPs.

  2. 4.02 The FASB Accounting Standards Codification (ASC) glossary defines cash equivalents as short-term, highly liquid investments that have both of the following characteristics: (a) readily convertible to known amounts of cash [and] (b) so near their maturity that they present insignificant risk of changes in value because of changes in interest rates. Generally, only investments with original maturities of three months or less qualify under that definition. Original maturity means original maturity to the entity holding the investment. For example, both a three-month U.S. Treasury bill and a three-year Treasury note purchased three months from maturity qualify as cash equivalents. However, a Treasury note purchased three years ago does not become a cash equivalent when its remaining maturity is three months. Examples of items commonly considered to be cash equivalents are Treasury bills, commercial paper, money market funds, and federal funds sold (for an entity with banking operations).

    5.103 NFPs may receive communications that are intentions to give, rather than promises to give. For example, communications from individuals indicating that the NFP has been included in the individual’s will as a beneficiary are intentions to give. Such communications are not unconditional promises to give, because individuals retain the ability to modify their wills during their lifetimes. (When the probate court declares the will valid, the NFP should recognize contribution revenue and a receivable at the fair value of its interest in the estate, unless the promise is conditional, in which case a contribution should not be recognized until the conditions are substantially met.) Paragraphs 49–51 of FASB ASC 958-605-55 provide an example of an individual naming an NFP as a beneficiary in her will. NFPs should disclose information about conditional promises in valid wills in conformity with FASB ASC 958-310-50-4. In cases in which the testator has not placed a purpose restriction on the gift, the net asset classification of the contribution revenue from a bequest differs in practice among NFPs. Some have concluded that because the contribution is in receivable form and will be paid at a future date, it is inherently time-restricted and therefore should be recognized as donor-restricted support. Others have concluded that because restrictions can only be placed by donors and the receivable is due and payable on the date the will cleared probate, the contribution revenue is not donor restricted. The latter say that although there may be time delays between clearing probate and payment because of administrative dealings of the courts and attorneys, those delays are not the actions of donors, and the timeline is not a function of a time restriction placed by a donor. NFPs should consider the facts and circumstances in determining the classification of the contribution revenue.

    5.104 Per FASB ASC 958-605-25-10, solicitations for donations that clearly include wording such as “information to be used for budget purposes only” or that clearly and explicitly allow resource providers to rescind their indications that they will give are intentions to give rather than promises to give and should not be reported as contributions.

    5.105 Recognized contributed services should be reported as contribution revenue and as assets or expenses. Whether such contributions should be recognized is unaffected by whether the NFP could afford to purchase the services at their fair value.

Excerpts from the 2019 Checklists and Illustrative Financial Statements Not-for-Profit Entities

C. Taxes, Part I. General

  1. Does the NFP disclose the following information about its tax status?
    1. Reference to the Internal Revenue Code section under which the NFP is exempt
    2. Whether the NFP is classified as a private foundation [Common Practice]
  2. If the NFP’s tax exempt status is in question by the IRS, is the potential impact disclosed?

    [FASB ASC 958-450-25-1]

  3. If the NFP incurs income tax expense, do the notes to the financial statements disclose the amount of the taxes and describe the nature of the activities that generated the taxes?

    [FASB ASC 958-720-50-1]

  4. If the NFP incurs income tax expense, do the notes to the financial statements include the disclosures required by FASB ASC 740, Income Taxes?

    [FASB ASC 740-10-15-2; FASB ASC 740-10-50]

  5. If the NFP has incurred any income tax penalties or interest, has it disclosed the total amounts of interest and penalties recognized in the statement of activities and the total amounts of interest and penalties recognized in the statement of financial position?

    [FASB ASC 740-10-50-15]

  6. If the NFP has unrecognized tax benefits, has it displayed the benefits as required by paragraphs 10A–12 of FASB ASC 740-10-45 and disclosed the information about those benefits required by FASB ASC 740-10-50-15? (Note: NFPs that are public entities are subject to additional requirements of FASB ASC 740-10-50-15A.)

    [FASB ASC 740-10-50-15; FASB ASC 740-10-45; Q&A 5250.15]

C. Investments Other Than Derivative Instruments, Part II. Statement of Financial Position

  1. Does the NFP disclose all of the following information about its alternative investments for which ownership is represented by units of investments, such as shares of stock or partnership interests, for each interim and annual period, separately for each class of investment?
    1. The fair value (as determined by applying paragraphs 59–62 of FASB ASC 820-10-35) of the investments in the class?
    2. A description of the significant investment strategies of the investee(s) in the class?
    3. For each class of investment that includes investments that can never be redeemed with the investees, but the NFP receives distributions through the liquidation of the underlying assets of the investees, the period of time over which the underlying assets are expected to be liquidated by the investees if the investee has communicated the timing to the NFP or announced the timing publicly, or if the timing is unknown, that fact?
    4. The amount of the NFP’s unfunded commitments related to investments in the class?
    5. A general description of the terms and conditions upon which the investor may redeem investments in the class (for example, quarterly redemption with 60 days’ notice)?
    6. The circumstances in which an otherwise redeemable investment in the class (or a portion thereof) might not be redeemable (for example, investments subject to a lockup or gate)?
    7. When a restriction from redemption might lapse for those otherwise redeemable investments that are restricted from redemption as of the measurement date if the investee has communicated that timing to the NFP or announced the timing publicly, that fact and how long the restriction has been in effect?
    8. Any other significant restriction on the ability to sell investments in the class at the measurement date?
    9. The plans to sell and any remaining actions required to complete the sale of any group of investments that would otherwise meet the criteria for probable sale except that the individual investments to be sold have not been identified? (The disclosure is made so the investments continue to qualify for the practical expedient in FASB ASC 820-10-35-59.) [FASB ASC 820-10-50-6A; “Pending Content” in FASB ASC 820-10-50-6A]

E. Donated or Contributed Services, Part III. Statement of Activities

  1. If the NFP receives contributed services, does it disclose the following?
    1. A description of the programs or activities for which those services were used
    2. The nature and extent of contributed services received for the period
    3. The amount recognized as revenues for the period
    4. The fair value of contributed services received but not recognized, if practicable (optional)
    5. Nonmonetary information such as the number and trends of donated hours received or service outputs provided by volunteer efforts (optional)
    6. Dollar amount of contributions raised by volunteers (optional) FASB ASC 958-605-50-1]

F. Accounts, Notes, Contributions, and Loans Receivable, Part II. Statement of Financial Position

  1. If the NFP received unconditional promises to give, does it disclose the following?
    1. The amounts of promises receivable in less than one year, in one to five years, and in more than five years
    2. The face amount of contributions promised to the NFP
    3. The amount of any allowance for uncollectible promises receivable
    4. Unamortized discount
    5. Amounts pledged as collateral or otherwise limited as to use [FASB ASC 958-310-50-1; FASB ASC 860-30-50-1A]

H. Contributions, Part III. Statement of Activities

  1. Does the NFP distinguish between contributions received with donor-imposed restrictions and those received without donor-imposed restrictions, so that they are reported as donor-restricted support that increases net assets with donor restrictions or support that increases net assets without donor restrictions, respectively?

    [“Pending Content” in FASB ASC 958-605-45-3]

  2. If donor-restricted contributions whose restrictions are met in the same reporting period are reported as support within net assets without donor restrictions, is such treatment consistent from period to period, is the policy disclosed, and does the NFP have a similar policy for the reporting of gains and investment income?

    [“Pending Content” in FASB ASC 958-220-45-6; “Pending Content” in FASB ASC 958-605-45-4]

  3. If donor-restricted contributions were initially conditional contributions and both the condition and the restriction have been met in the current period, has the NFP reported consistently from period to period and disclosed its accounting policy if it elects to report those contributions as support within net assets without donor restrictions? Note: An NFP may elect this policy without also having to elect it for other donor-restricted contributions or investment gains and income.

    [“Pending Content” in FASB ASC 958-605-45-4B]

  4. Does the NFP report receipt of unconditional promises to give with payments due in future periods as donor-restricted support, unless explicit donor stipulations or circumstances surrounding the receipt of the promise make clear that the donor intended the contribution to be used to support activities of the current period?

    [“Pending Content” in FASB ASC 958-605-45-5]

J. Risks and Uncertainties, Part I. General

  1. Is an explanation that the preparation of financial statements in conformity with GAAP requires the use of management’s estimates included in the financial statements?

    [FASB ASC 275-10-50-4]

J. Expenses, Part III. Statement of Activities

  1. Are payments to affiliated NFPs reported by their functional classification to the extent that it is practicable and reasonable to do so?

    [FASB ASC 958-720-45-26]

  2. Are payments to affiliates that cannot be allocated to functions treated as a separate supporting service and reported in the statement of activities as a separate line item, and labeled “unallocated payments to affiliated NFPs”?

    [FASB ASC 958-720-45-26]

R. Fair Value Measurements, Part I. General

Required — Case study 4

Using the excerpts from the 2020 AICPA Audit and Accounting Guide Not-for-Profit Entities, the excerpts from the 2019 Checklists and Illustrative Financial Statements Not-for-Profit Entities, and your experience and knowledge of NFP GAAP, verify whether the following selected disclosures meet the minimum requirements per GAAP. If a disclosure (or element of a disclosure) is missing, create a sample disclosure.

Selected financial statement disclosures

1. Basis of presentation

The preparation of financial statements in conformity with accounting principles generally accepted in the United States of America requires management to make estimates and assumptions that affect certain reported amounts and disclosures. Accordingly, actual results could differ from those estimates.

Financial statement presentation follows the accounting standard requirements for not-for-profit organizations. Under these standards, an organization is required to report information regarding its financial position and activities according to two classes of net assets depending on the existence and/or nature of any donor restrictions as follows: net assets without donor restrictions and net assets with donor restrictions.

Net assets with donor restrictions include restricted contributions received. When donor restrictions expire (that is, when a stipulated time restriction ends or purpose restriction is met), net assets with donor restrictions are reclassified to net assets without donor restrictions and reported in the statement of activities as net assets released from restrictions. However, if a restriction is fulfilled in the same time period in which the contribution is received, the Foundation reports that support as net assets without donor restrictions.

2. Revenue recognition

Contributions of cash and other assets received are recorded as increases in net assets with or without donor restrictions depending on the existence and nature of any donor restrictions.

All net assets with donor restrictions are reported as increases in net assets with donor restrictions. When a restriction expires (that is, when a stipulated time restriction ends or purpose restriction is met), net assets with donor restrictions are reclassified to net assets without donor restrictions and reported in the statement of activities as net assets released from donor restrictions.

A number of people have contributed significant amounts of time to the activities of the Foundation. The financial statements do not reflect the value of these contributed services because they do not meet the criteria for recognition.

The Foundation is a controlled affiliate of the ABC NFP. ABC NFP provides administrative support and fundraising services for which it did not charge the Foundation. The Foundation recognized revenue and related expenses for contributed services from the Association based on the estimated fair value of those services.

3. Income taxes

The Foundation is organized as a not-for-profit organization exempt from federal income tax under Section 501(c) (3) of the Internal Revenue Code. The Foundation also meets the requirements of Section 509(a) (1) of the Internal Revenue Code and is therefore not a private foundation.

The Foundation has no unrecognized tax benefits at June 30, 2019. As of June 30, 2019, the Foundation did not recognize any interest and penalties associated with tax matters.

4. Note X — Fair value measurements

The framework for measuring fair value provides a fair value hierarchy that prioritizes the inputs to valuation techniques used to measure fair value. The hierarchy gives the highest priority to unadjusted quoted prices in active markets for identical assets or liabilities (level 1) and the lowest priority to unobservable inputs (level 3). The three levels of the fair value hierarchy are described as follows:

Level  1:Inputs to the valuation methodology are unadjusted quoted prices for identical assets or liabilities in active markets that the Foundation has the ability to access.
Level  2:Inputs to the valuation methodology include:
  • quoted prices for similar assets or liabilities in active markets;
  • quoted prices for identical or similar assets or liabilities in inactive markets;
  • inputs other than quoted prices that are observable for the assets or liabilities;
  • inputs that are derived principally from or corroborated by observable market data by correlation or other means.

If the asset or liability has a specified (contractual) term, the level 2 input must be observable for substantially the full term of the asset or liability.

Level  3:Inputs to the valuation methodology are unobservable and significant to the fair value measurement.

The asset’s or liability’s fair value measurement level within the fair value hierarchy is based on the lowest level of any input that is significant to the fair value measurement. Valuation techniques maximize the use of observable inputs and minimize the use of unobservable inputs.

The following table sets forth by level, within the fair value hierarchy, the Foundation’s assets at fair value as of June 30, 2019:

Assets at Fair Value as of June 30, 2019
  Level 1 Level 2 Level 3 Total
Mutual Funds $ 4,000,000 $ - $ - $ 4,000,000
Exchange Traded Funds $ 1,500,000 $ - $ - $ 1,500,000
Preferred Stock $ - $ - $ 1,000,000 $ 1,000,000
Total Assets in FV Hierarchy $ 5,500,000 $ - $ 1,000,000 $ 6,500,000
         
Investments measured at NAV $ - $ - $ - $ 750,000
         
Total investments at fair value $ 5,500,000 $ - $ 1,000,000 $ 7,250,000

The following table sets forth a summary of changes in fair value of the Foundation’s level 3 assets for the year ended June 30, 2019:

Balance, July 1, 2019 $ 200,000
Unrealized gain 800,000
Balance, June 30, 2019 $ 1,000,000

These investments were classified as level 3 assets because the Foundation used unobservable inputs to value them, reflecting the Foundation’s assessment of the assumptions market participants would use in pricing these investments due to the absence of quoted market prices and inherent lack of liquidity.

The preceding methods described may produce a fair value calculation that may not be indicative of net realizable value or reflective of future fair values. Furthermore, although the Foundation believes its valuation methods are appropriate and consistent with other market participants, the use of different methodologies or assumptions to determine fair value of certain financial instruments could result in a different fair value measurement at the reporting date.

5. Note Y — Net assets

Net assets as of June 30, 2019:

Without donor restrictions  
 Board designated - scholarships $    750,000
 Unrestricted $ 10,000,000
   
  $ 10,750,000
   
With donor restrictions  
 Scholarships $ 3,000,000
 Community Outreach $  500,000
 Diversity & Inclusion Initiative $  375,000
   
  $  3,875,000
   
Total net assets $ 14,625,000

Net assets were released from donor restrictions by incurring expenses satisfying the following purpose restrictions:

Diversity and inclusion initiative $ 50,000.00
Community Outreach 500,000.00
Release of net assets with donor restrictions $ 550,000.00
6. Pledges Receivable, Net –

Unconditional promises to give that are expected to be collected within one year are recorded at net realizable value. Unconditional promises to give that are expected to be collected in future years are recorded at the present value of their estimated future cash flows. The discounts on those amounts are computed using risk-adjusted rates. Amortization of the discounts is included in contributions revenue. An allowance for doubtful accounts is based on specific identification of possible uncollectible accounts and the Foundation’s historical collection experience.

Knowledge check

  1. Which is not a required disclosure for fair value?
    1. The level within the fair value hierarchy level.
    2. Purchases, sales, and issuances of Level 3 investments.
    3. The reason for purchasing the investments.
    4. The fair value measurements at the end of the reporting period.
  2. Which is not a required disclosure for investments measured using NAV?
    1. A description of the terms and conditions upon which the investor may redeem investments.
    2. The name of other investors who are also invested in the investment.
    3. The amount of the reporting entity’s unfunded commitments.
    4. Significant restrictions on the ability to sell investments.
  3. Which is not a required disclosure for unconditional promises to give?
    1. The amount of receivables in less than one year, in one to five years, and in more than five years.
    2. The amount of the allowance for uncollectible accounts.
    3. The entities with significant past due balances.
    4. The discount on contributions receivable that arises when the contribution is measured using a present value method.
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