CCMA CALIFORNIA COMMITTEE ON MUNICIPAL ACCOUNTING April 2000 To: City Finance Officers, CPAs and Other Interested Parties From: The California Committee on Municipal Accounting Subject: CCMA WHITE PAPER Accounting and Financial Reporting for Loans between California Cities and Related Redevelopment Agencies GASB Statement No. 34 requires changes in the way California cities account for loans between a city and its redevelopment agency. GFOA has recommended that these loan transactions be excluded from the General Long-term Debt Account Group of the CAFRs that are submitted for the GFOA award. This white paper provides guidance on applying these new rules in California. The paper also contains suggested language on how a city should respond to the GFOA if it receives a GFOA CAFR award comment suggesting that this accounting change be made prior to the implementation of GASB Statement No. 34. The California Committee on Municipal Accounting is comprised of representatives of the California Society of Certified Public Accountants and the League of California Cities. The purpose of CCMA is to serve the public interest by providing the highest degree of sound financial administration and ensuring the fullest cooperation between city officials and members of the independent accounting profession. Other CCMA publications may be obtained by using the order form on the back of this page. If you have questions concerning CCMA, please call Dan Harrison in the League’s Sacramento office at 916-658-8267. Now Available: The CCMA White Papers Available from the League of California Cities for $5 each. CCMA White Papers All prices include shipping and sales tax -- prepayment is required Quantity of each paper you wish to order: ___Accounting for Taxpayer-assessed Tax Revenues in Governmental Funds (1995) ___Agreed-upon Procedures Applied to the Appropriations Limitation Prescribed by Article XIII-B of the California Constitution (1997) ___Agreed-upon Procedures Applied to Investment Portfolios of Local Government (1997) ___Accounting for Pensions for State and Local Governments (1997) ___Auditing Procedures to Consider in the Evaluation of the Sufficiency of Disclosure of the Impact of Proposition 218 on the Financial Statements of a Local Government in the State of California (1998) ___Accounting and Financial Reporting for Loans Between California Cities and Related Redevelopment Agencies (1999) TOTAL: ____ (total # of papers) @ $5 each = $________ Name _____________________________________________ Organization________________________________________ Title ______________________________________________ Street Address (no P.O. Box please) ____________________ Name of Card Holder_______________________________ ___________________________________________________ VISA/MC Card No. _______________________________ City _______________________ State ____ Zip _________ Signature ________________________________________ Telephone ________________________________________ Expiration Date ___________________________________ Please make checks payable to: League of California Cities Mail Payment to: League of California Cities, Attn: Publications Unit, 1400 K Street, Sacramento, CA 95814 Credit card orders may be faxed to: 916/658-8240 g:\mss\member\rid\ccma\whiteord.doc CCMA Members California Society of CPAs Mike Morehead, Co-chair Ken Al-Imam Clyde Brown Mollie Marshall League of California Cities Derek Hanway, Co-chair Barbara Hennessy Larry Hurst Nick Rives Rob Stout ACCOUNTING AND FINANCIAL REPORTING FOR LOANS BETWEEN CALIFORNIA CITIES AND RELATED REDEVELOPMENT AGENCIES Revised May 1999 PUBLISHED BY THE CALIFORNIA COMMITTEE ON MUNICIPAL ACCOUNTING (a joint committee comprised of representatives of the League of California Cities and the California Society of Certified Public Accountants) ACCOUNTING AND FINANCIAL REPORTING FOR LOANS BETWEEN CALIFORNIA CITIES AND RELATED REDEVELOPMENT AGENCIES I. INTRODUCTION Purpose of Paper One of the most significant transactions occurring between California cities and their redevelopment agencies is loans (or advances) from the City to the redevelopment agency. Millions of dollars in loans are made and repaid each year subject to a variety of loan repayment provisions. As a result, questions have arisen regarding the accounting and financial reporting treatment of these loans. In April of 1987, the California Committee on Municipal Accounting published its “white paper” on this topic, entitled Accounting and Financial Reporting for Loans Between California Cities and Related Redevelopment Agencies. In May of 1996, this white paper was revised and reissued. The position of these prior white papers was that long-term loans from the City to the Redevelopment Agency should be reported as a liability in the Agency’s General Long-term Debt Account Group. As a result of GASB Statement No. 34 and certain recommendations made by GFOA, this accounting will no longer be appropriate. The Special Review Executive Committee (SREC) of the Government Finance Officers Association (GFOA) is responsible for overseeing the operations of the Government Finance Officers Association (GFOA) Certificate of Achievement for Excellence in Financial Reporting Program. In June of 1998, the SREC issued a program policy statement calling for certain changes in the reporting of loans between a primary government and its component unit. Specifically, the SREC adopted the following new program policy for those governments submitting for the GFOA award: Governments currently reporting long-term interfund liabilities in the General Long-Term Debt Account Group (GLTDAG) of the CAFR’s submitted for the GFOA award may continue to report those specific liabilities in the GLTDAG of the CAFR submitted by the reporting entity as a whole. These governments may also apply this same treatment to interfund liabilities incurred prior to fiscal year 1999. However, all such liabilities incurred after fiscal year 1999 (on or after July 1, 1999) will need to be reported in the appropriate governmental fund. Governments that historically have not reported long-term interfund liabilities in the GLTDAG will be precluded henceforth from doing so as a matter of program policy. For purposes of preparing the CAFR for the reporting entity as a whole, GFOA believes that the reporting recommended by the SREC should be applied at a minimum to all loans from the City to the Redevelopment Agency incurred on or after July 1, 1999. GFOA also has indicated that failure to apply SREC guidelines to such transactions will result in a GFOA award comment for those local governments submitting for the GFOA award. However, GFOA has indicated that such comments will not result in the denial of the GFOA award for that government as long as that government responds to the GFOA award comment in a manner similar to the following: “The reporting government intends to implement the SREC guidance regarding these transactions in conjuction with the entity’s implementation of GASB Statement No. 34. Accordingly, these changes will be made on the effective date required by GASB for GASB Statement No. 34.” 2 CCMA recommends that whenever a City chooses to implement the SREC guidance, that the accounting recommended by the SREC be applied not only to the new loans, but that this guidance also be retroactively applied to loans previously funded by the City that are still outstanding (in order to promote consistency of accounting treatment for all transactions similar in nature). CCMA also recommends that all local governments follow the guidance of the SREC (in conjunction with the implementation of the new financial reporting model), not just those governments submitting for the GFOA award. In order to minimize confusion to the reader and to facilitate financial statement preparation, CCMA also recommends that the separate component unit Redevelopment Agency financial statements use the same reporting that is recommended by GFOA for the CAFR of the reporting entity as a whole. Accordingly, this white paper has been revised to reflect this new accounting treatment (to be used both in the separate RDA financial statements and in the CAFR of the reporting entity as a whole). The State Controller’s Office has indicated that it will accept the reporting recommended in this white paper both for purposes of submitting separate audited financial statements to the State Controller’s Office for redevelopment agencies within California and for preparation of the State Controller’s Report for those agencies. On the forms used for the State Controller’s Report, the loans owed to the City could be shown on the loans payable line in the column established for debt service funds. Materiality The provisions of this paper need not be applied to immaterial items. Consistency The accounting principles discussed in this paper should be followed consistently from year to year. The implementation of these principles and changes in the application of these principles from year to year, if material, could result in prior period adjustments and a consistency qualification in the independent auditors’ report. Authoritative References The following authoritative references relate to the accounting and reporting issues discussed herein and are provided for the convenience of the reader: a. Measurement Focus of Governmental Funds (GASB Cod. Sec. 1300.102a): “...The governmental fund measurement focus is on determination of financial position and changes in financial position (sources, uses, and balances of financial resources), rather than on net income determination. The statement of revenues, expenditures, and changes in fund balance is the primary governmental fund operating statement. It may be supported or supplemented by more detailed schedules of revenues, expenditures, transfers, and other changes in fund balance.” Accounting for Fund Balance Reserves (GASB Cod. Sec. 1800.123): “...The use of the term ‘reserve’ should be limited to indicating that a portion of the fund balance is not appropriable for expenditure or is legally segregated for a specific future use.” b. Revenue Recognition Criteria (GASB Cod. Sec. 1600.106): Generally, revenues are not recognized unless they are both “measurable” and “available”. Available means received during the current fiscal year, or soon enough 3 after year end to be used to pay liabilities of the current year. Each governmental unit should adopt its own policies to implement the measurable and available criteria, and apply them consistently. Revenues earned by Proprietary Funds are recognized in essentially the same manner as in commercial accounting, i.e., on the accrual basis. c. Operating Transfers Between Component Units (GASB Cod. Sec. 2600.120): Operating transfers between the primary government and its component units have historically been reported as intergovernmental revenues, operating revenues/expenditures/expenses and/or as operating transfers. For presentation within the financial statements of the reporting entity, such operating transfers should be reported as if they were between funds of the primary government. d. Related Receivables and Payables (GASB Cod. Sec. 2600.120): Related receivables and payables between what were previously separately reported governmental units, which are included as component units of a reporting entity, should be reclassified as amounts due to and due from other funds. II. RECOMMENDED ACCOUNTING POLICIES - SEPARATE STATEMENTS The accounting and reporting recommended by CCMA below relates to both the separate financial statements of a Redevelopment Agency, as well as the reporting of the reporting entity as a whole (in the general purpose financial statements of the reporting entity). This section has been divided to address the following accounting issues: 1. Short-term loans 2. Long-term loans 3. Revolving loans 1. SHORT-TERM LOANS Short-term loans are those that are to be repaid from “available current financial resources”. Such resources would typically include proceeds from the sale of land held for resale or interest earnings on investments, but would not include tax increment revenue. The required entries to record short-term loans are as follows: CITY (GOVERNMENTAL) FUND Due from Redevelopment Agency Cash 1,000,000 1,000,000 RDA CAPITAL PROJECTS FUND Cash Due to City of ____________ 1,000,000 1,000,000 When the loans are repaid, the entries above would be reversed. Occasionally, the City may make a loan to the Agency that is to be repaid within the same fiscal year or shortly after year-end from tax increment monies to be received by the Agency during the fiscal year. In these cases, the short-term borrowing would be treated similar to revenue anticipation debt (i.e., as a fund liability). However, since the source of repayment is 4 normally received in the debt service fund, additional entries are required to record the transfer of funds from the debt service fund to the capital projects fund as follows: RDA DEBT SERVICE FUND Operating transfers out Cash 1,000,000 1,000,000 RDA CAPITAL PROJECTS FUND Cash Operating transfers in 1,000,000 1,000,000 2. LONG-TERM LOANS Long-term loans are those that are to be repaid from future resources, i.e., not from “available current financial resources”. A reserve of fund balance is made for the long-term receivable in the City Fund (lender), as these funds are not available to finance current operations. The RDA should not record the receipt of the loan proceeds as an other financing source, as was done prior to the implementation of GASB Statement No. 34. After the implementation of GASB Statement No. 34, the RDA’s receipt of the loan proceeds should be recorded as a liability of the fund responsible for repayment, i.e. the debt service fund. The cash associated with this borrowing should then be transferred to the capital projects fund so that it can be expended for project purposes as required by state law. The required entries to record long-term loans are as follows: CITY (GOVERNMENTAL) FUND Advances receivable Cash 1,000,000 Fund balance—Unreserved Fund balance—Reserved for long-term advances 1,000,000 1,000,000 1,000,000 RDA DEBT SERVICE FUND Cash Advances payable 1,000,000 Operating transfers out Cash 1,000,000 1,000,000 1,000,000 RDA CAPITAL PROJECTS FUND Cash Operating transfers in 1,000,000 1,000,000 When the advance is repaid, the following entries are required: 5 CITY (GOVERNMENTAL) FUND Cash Advances receivable 1,000,000 Fund balance—Reserved for long-term advances Fund balance—Unreserved 1,000,000 1,000,000 1,000,000 RDA DEBT SERVICE FUND Advances payable Cash 1,000,000 1,000,000 3. REVOLVING LOANS Revolving loans are those loans made on an ongoing basis, where repayment is sporadic or otherwise unscheduled. Typically, these loans are associated with administrative charges made by the City to the Agency for salary and overhead costs allocable to the Agency. The loans usually accumulate and are repaid from future tax increment revenues as they become available. The required entries to record revolving loans are as follows: CITY (GOVERNMENTAL) FUND Advances receivable Administrative costs recovered (revenue) 1,000,000 Fund balance—Unreserved Fund balance—Reserved for long-term advances 1,000,000 1,000,000 1,000,000 As an alternative, the credit above to revenue could be made against the appropriate expenditure accounts, particularly in the combined financial statements, in order to avoid the double counting of administrative and overhead expenditures. The liability is recorded in the Redevelopment Agency fund responsible for repayment (the debt service fund). An operating transfer out is then recorded into the capital projects fund in order to provide for the recording in that fund of the administrative costs being incurred for the project: RDA DEBT SERVICE FUND Operating transfers out Advances payable 1,000,000 1,000,000 RDA CAPITAL PROJECTS FUND Administrative costs Operating transfers in 1,000,000 1,000,000 When advances are repaid from tax increment revenue, the entries required are the same as shown above for “long-term loans”. 6 Entries to record direct charges to the Redevelopment Agency: When administrative costs are charged directly to the Redevelopment Agency Capital Projects Fund through automated payroll journal entries, etc., additional entries must be made in the City and Agency funds to record the loan and effects on cash at the time of the payroll journal entry. Assume a direct monthly charge of $10,000. CITY (GOVERNMENTAL) FUND Advances receivable Cash 10,000 Fund balance—Unreserved Fund balance—Reserved for long-term advances 10,000 10,000 10,000 RDA DEBT SERVICE FUND Cash Advances payable 10,000 Operating transfers out Cash 10,000 10,000 10,000 RDA CAPITAL PROJECTS FUND Cash Operating transfers in 10,000 10,000 III. UNPAID ACCRUED INTEREST Unpaid accrued interest on loans between a City and a Redevelopment Agency can result from the following: 1. The accrued interest is due, but will not be paid currently as sufficient funds are unavailable to meet the interest payment (i.e., the interest payment is delinquent); or 2. The accrued interest is not due, but payable in future years. Each of these scenarios is discussed below. 1. ACCRUED INTEREST DUE BUT UNPAID When accrued interest is “due” but goes unpaid because of unavailable Redevelopment Agency funds, the City will typically agree to add the unpaid interest to the outstanding balance through a refinancing of, or an amendment to, the existing loan. Subsequent interest will be calculated based on the adjusted balance (which includes the accumulated unpaid accrued interest). However, the recommended treatment discussed below is not affected by the method used to calculate subsequent accrued interest (compound vs. simple method). Based on the above, the unpaid accrued interest would be recorded when incurred as an addition to the recorded liability in the debt service fund, as shown in the following entries: RDA DEBT SERVICE FUND 7 Interest expenditures Advances payable 100,000 100,000 CITY (GOVERNMENTAL) FUND Advances receivable Deferred revenue 100,000 100,000 Because the interest included above within the Advances Receivable is not available to finance current operations, it is offset by a corresponding entry to deferred revenue. Footnote disclosures of both Advances Receivable and Advances Payable balances in the City and Agency financial statements, respectively, may disclose the accumulated accrued, but unpaid, interest amounts included within the respective balances. When the accumulated unpaid accrued interest is ultimately repaid, the following entries are required: CITY (GOVERNMENTAL) FUND Cash Advances receivable 100,000 Deferred revenue Interest revenue 100,000 100,000 100,000 RDA DEBT SERVICE FUND Advances payable Cash 1,000,000 1,000,000 As a less preferable alternative, the unpaid accrued interest can be disclosed in the footnotes each year, but not added to the liability recorded in the debt service fund. The interest would then be recorded as an expenditure in the debt service fund only in the year paid. 2. ACCRUED INTEREST NOT DUE AND UNPAID Loan agreements between a City and its Redevelopment Agency may provide that interest on loans is payable at a specified date in the future or otherwise “when sufficient tax increment revenues are available”. 1. In general when accrued interest is not paid simply because it is NOT DUE, then the Redevelopment Agency should apply the same treatment described above for unpaid interest that is due (i.e., treating the interest as accrued and added to the liability recorded in the fund responsible for repayment—the debt service fund). 2. If the repayment of interest (and/or principal) is dependent upon the availability of future tax increment revenues, treatment would be the same as “1.” above, unless the likelihood of future tax increment being available is remote and the City has agreed, by resolution, to forgive the entire debt. If the debt is forgiven, the City should record a loss, and the Redevelopment Agency should remove the forgiven liability from the balance sheet of the debt service fund and record as revenue the forgiveness of debt owed to the City (recorded as “contribution from the City”). 8