Institutional Retirement and Trust IASB introduces changes: New DB plan accounting standards by J. Sterling Price, FSA, BPS&M, Wells Fargo’s benefits consulting group If the last few years have taught us anything, it is that even the smallest of corporate balance sheets can be affected by global financial events. With concerns over the growing European debt crisis, and questions about overall global financial stability, it has become increasingly important for investment and banking professionals to be able to compare apples to apples when looking at an entity’s financial statements. In an effort to make this possible, the International Accounting Standards Board (IASB) has created International Financial Reporting Standards (IFRS), the successor to International Accounting Standards (IAS). Over the years, these standards have evolved. A significant amendment to IAS 19 by the IASB dramatically changes the recognition and measurement of pension expense and termination benefits in defined benefit plans, as well as the disclosures of all employee benefits. While these changes will affect plan sponsors outside the U.S., the slowly developing convergence between IASB and the U.S. Financial Accounting Standards Board (FASB) could cause these new rules to impact U.S. domestic plan sponsors as well. The latest version of IAS 19, which was adopted in June of 2011, represents considerable movement toward even greater transparency in employer-provided pensions. The changes, which are effective for accounting periods beginning on or after January 1, 2013, will decrease the smoothing options previously available to plan sponsors and increase the visibility of pension risks and the reporting obligations of illustrating these risks. In contrast to prior rules, plan sponsors will not be rewarded with lower pension expense by assuming more risks. These changes, combined with the current volatile investment markets, may further motivate plan sponsors to consider options that decrease risk exposure in their plans. The contents of this report are for information purposes only. They should not be construed as professional, legal, or tax advice or opinions. These can be properly rendered only in the context of specific facts. In all cases, you should consult your professional, legal, or tax advisors if you have questions about your individual situation. Neither Wells Fargo, nor any of its representatives, may give legal or tax advice. Key changes resulting from this amendment Recognition of actuarial gains and losses. Actuarial gains and losses will be reclassified as “Remeasurements” and will be recognized immediately. Actuarial gains and losses will no longer be deferred using a corridor approach, which amortizes “extreme” gains or losses, or recognized in the profit and loss (P&L) statement. This will likely increase the volatility of the sponsor’s balance sheet. Recognition of past service cost/curtailment. Past service costs (created when a plan is amended to increase or decrease benefits) will be recognized at the time of a plan amendment. Plan sponsors will no longer be allowed to spread unvested benefits over a period of expected future service. Curtailments will now only occur when a plan sponsor significantly reduces the number of employees. Gains and losses emerging from curtailments will be accounted for as past service costs. Measurement of pension expense. Annual expense for a funded benefit plan will consist of the net interest expense or income which is calculated by applying the discount rate to the net asset or liability. This will replace the interest cost and expected return on assets, essentially replacing the expected rate of return of assumption with the discount rate assumption. The discount rate will still be based on a high-quality corporate bond rate where there is a deep market for such bonds. A government bond rate should be used for those markets where such corporate bonds do not exist. This could have a dramatic effect on P&L statements. Income statement presentation. There will be less flexibility available for disclosure of items in a plan sponsor’s income statement. Benefit expense will split between the service cost (current period benefits), benefit changes (from curtailments, past service cost changes, and settlements), and finance expense and income. Analysis of these items can be placed in the income statement itself or the footnotes. Disclosure requirements. Plan sponsors will be required to present the following additional information concerning their benefit plans. Key plan •Plancharacteristics,includingthenature characteristics ofbenefits,regulatoryframework(suchas and risks minimum funding requirements) and their effect on the plan •Descriptionofanyunusualoremployerspecific plan risks Explanation of amounts in financial statements Detailsof cashflow •Showchangesindemographicand financial assumptions separately •Showsettlementsandadministrationcosts separately from other payments •Split“netinterestcost”intoeffectonplan assets,obligation,andassetceiling •Sensitivityanalysisforeachsignificant actuarial assumption •Discussasset-liabilitymatchingstrategies •Discussfundingarrangements andpolicies thataffectfuturecontributionsweighted averagedurationofbenefitobligationand relevantmaturityinformation Clarification of measurement issues. The amendment provides clarification on several items and how they must be treated in the measurement of the company’s obligations. These include: • Significanteventsandhowtheyrelatedto – Past service costs – Settlements and curtailments – Timing of recognition • Treatmentoftaxes • Treatmentofexpenses • Sharedcostplans • Classificationofbenefitsplans – Long term vs. short term Possible implications of the amendment to IAS 19 In addition to the increased reporting and calculation requirements brought forth by the amendment, the amendment may also: • Discourageequityinvestments,therebyincreasingthe weight of fixed income investments within the portfolio • Encourageaggressiveassumptionsduetothechangein how actuarial gains and losses will be treated • Leadtofurtherclosuresofdefinedbenefitplansinaneffort to decrease balance sheet volatility • Placemorefocusonthemethodologyusedforselecting the discount rate • Rewardgoodriskmanagementthroughenhanceddisclosure of risks and how they are managed Comparison with FASB Accounting Standards Codification 715 U.S. companies are subject to accounting for their employee benefit plans under FASB Accounting Standards Codification 715 (ASC 715). There are some similarities and some significant differences between the two standards after the IAS 19 amendment. The following table indicates whether FASB, IASB, or both standards apply to specific accounting treatments. FASB IASB Treatment of balance sheet liabilities Yes Yes “Recycling”ofgains and losses Yes No Interest cost minus expected return Yes No Finance cost of surplus or deficit No Yes Immediate recognition of cost of amendments No Yes Lump sums are considered a settlement if part of normal business routine Yes No While it remains a long-term goal of both the FASB and the IASB to reach a level of convergence in accounting for employee pensions, a set timetable does not exist. DB plan sponsors in the U.S. should continue to monitor developments from the IASB in order to be prepared if, and when, the boards decide to formally unify standards. J. Sterling Price FSA, EA, MAAA Sterling has more than 13 years of actuarial and consulting experience related to the design, funding, administration, and regulatory compliance of retirement plans. He has experience with both qualified and nonqualified retirement plans. Sterling has worked with a wide range of clients including governmental entities, church groups, and private employers. The contents of this report are for information purposes only. They should not be construed as professional, legal, or tax advice or opinions. These can be properly rendered only in the context of specific facts. In all cases, you should consult your professional, legal, or tax advisors if you have questions about your individual situation. Neither Wells Fargo, nor any of its representatives, may give legal or tax advice. © 2012 Wells Fargo Bank, N.A. All rights reserved. Member FDIC. ECG-710678 590264