New Expanded Disclosures

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1 September 2010 Expanded Disclosures About Credit Quality of Financing Receivables and Allowance for Credit Losses Required as Early as 2010 Accounting Insights is a publication of McGladrey & Pullen, LLP and should not be construed as accounting, auditing, consulting, or legal advice on any specific circumstances or facts. The contents are intended for general information purposes only. You are urged to consult your McGladrey service provider concerning your situation and any specific questions you may have. On July 21, 2010 the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU) No , Disclosures about the Credit Quality of Financing Receivables and the Allowance for Credit Losses. This ASU amends Accounting Standards Codification Topic 310, Receivables, and requires expanded disclosures about the credit quality of an entity s loan, lease and other financing receivables and its related allowance for credit losses. These new disclosures will significantly expand the existing requirements and are focused on providing financial statement users more information to understand an entity s exposure to credit losses and how the allowance relates to that exposure. A significant change from the current disclosure requirements will be the need to provide information on financing receivables and the related allowance for credit losses on a more detailed basis. The expanded levels are referred to as portfolio segment and class of financing receivables. A class of financing receivables is generally a further break down of a portfolio segment.

2 2 ASU We expect that management will need to design and implement new or expanded processes to meet the disclosure requirements of this new standard. We expect that management will need to design and implement new or expanded processes to meet the disclosure requirements of this new standard. These changes will include developing expanded reports from information systems and making modifications to any spreadsheets used to summarize the information. Management may need to execute completely new processes to obtain some of the data needed to meet the disclosure requirements. The focus of the ASU is additional disclosure of: The nature of credit risk, How credit risk is analyzed and assessed in arriving at the allowance for credit losses, and Changes and reasons for those changes in the allowance for credit losses. Descriptions and discussions of these items as well as accounting policies pertinent to the allowance for credit losses will need to be provided at the portfolio segment level. Additionally, existing disclosures about financing receivables will need to be presented in more detail by including: A schedule of the activity in the allowance for credit losses from the beginning of the reporting period to the end of the reporting period on a portfolio segment basis, with the ending balance further disaggregated on the basis of the whether the allowance is a general allowance or based on specific receivables For each disaggregated ending balance, the related recorded balance in financing receivables The nonaccrual status of financing receivables by class Impaired financing receivables by class Further, the following new disclosures about financing receivables will need to be presented: Credit quality indicators of financing receivables at the end of the reporting period by class The aging of past due financing receivables at the end of the reporting period by class The nature and extent of troubled debt restructurings that occurred during the period by class and their effect on the allowance for credit losses The nature and extent of financing receivables modified as a result of troubled debt restructurings within the previous 12 months that defaulted during the reporting period by class, and their effect on the allowance for credit losses Significant purchases and sales of financing receivables during the reporting period disaggregated by portfolio segment

3 ASU Preparing for Implementation A recommended action plan may include the following steps: Form an implementation team with representatives from management responsible for financial reporting as well as developing the allowance for credit losses and assessing and monitoring the risk in the portfolio. Representative(s) knowledgeable of system capabilities should also be involved and for those entities required to assess internal controls, it would also be a good idea to involve individuals responsible for the assessment. Outline specific tasks to be accomplished and assign accountability and deadlines for each. Agree on the classes of financing receivables and credit quality indicators that are most relevant to the organization. Determine the extent to which new requirements can be fulfilled with existing system reports or spreadsheets and the extent to which new reports, spreadsheets or processes will need to be developed or modified to accommodate those that can t be so fulfilled. Establish processes and controls for obtaining and reporting the additional information. Prepare a mocked up sample disclosure in advance of the required implementation date to obtain feedback/concurrence of constituents such as senior management, audit committee and auditors. Test controls in advance of the annual assessment date to allow time for remediation if warranted. The following appendices contain useful supplementary information. Appendix A answers many of the questions you face. Appendix B contains sample disclosures. The supplemental checklist included in Appendix C enumerates the disclosure requirements now contained in ASC The checklist also provides an explanation as to whether each disclosure requirement is new or existing, as well as summarizing the applicability to various financing receivables. ASU is available in full at In addition, the FASB has recorded a webinar, Financing Receivables Disclosures Update, which provides an overview of the ASU. The webinar is available through October 2010 on the FASB website. About McGladrey & Pullen, LLP McGladrey is the brand under which McGladrey & Pullen, LLP and RSM McGladrey, Inc. serve clients business needs. The two firms operate as separate legal entities in an alternative practice structure. McGladrey & Pullen is a licensed CPA firm providing assurance services. RSM McGladrey provides tax and consulting services. McGladrey & Pullen, LLP and RSM McGladrey, Inc. are members of the RSM International ( RSMi ) network of independent accounting, tax and consulting firms. The member firms of RSMi collaborate to provide services to global clients, but are separate and distinct legal entities which cannot obligate each other. Each member firm is responsible only for its own acts and omissions, and not those of any other party. McGladrey, the McGladrey signature, The McGladrey Classic logo, The power of being understood, Power comes from being understood and Experience the power of being understood are trademarks of McGladrey & Pullen, LLP and RSM McGladrey, Inc.

4 4 ASU Appendix A: Q & A Why did FASB issue this new guidance? Isn't this just a disclosure standard? What s the big deal? My company is not a bank or finance company. As such, is this update applicable? What exactly is a financing receivable? What is a portfolio segment and how does it compare to a class of financing receivable? This standard is the outcome of a project added to the board agenda in January 2007 to provide more timely guidance on the allowance for credit losses and related financing receivable disclosures. Previously, the American Institute of Certified Public Accountants Accounting Standards Executive Committee had a project underway to clarify the objectives of determining the allowance for credit losses, but later scaled back to only address disclosures. The major objectives of the project are to expand credit quality disclosures to provide more transparent information to investors, to incorporate into U.S. GAAP certain information that is already required by bank and securities regulators, and to more closely align U.S. GAAP with current IFRS disclosure requirements. While it is a disclosure standard, we expect that many companies will need to make system and other changes to be able to meet the new requirements in a relatively short period of time. Most of the disclosures will be required for public companies for periods ending after December 15, While nonpublic companies will not be required to comply until annual periods ending after December 15, 2011, information for disclosures about activity occurring in that period will need to be accumulated for transactions such as troubled debt restructurings occurring from the beginning of the period of adoption, which would be January 1, 2011 for calendar year companies. While the update applies to all entities, both public and nonpublic that report financing receivables as an asset, as summarized in Appendix C, the new disclosures do not apply to trade accounts receivable that arise from the sale of goods or services and have a contractual maturity of less than one year and receivables that are either measured at fair value or lower of cost or fair value. A financing receivable is defined as a recognized asset that represents a contractual right to receive money either on demand or on fixed or determinable dates. Loans, notes and trade accounts receivable are considered to be financing receivables, as well as credit card receivables and certain receivables relating to non- operating leases. Short-term trade accounts receivable and receivables measured at fair value or lower of cost or fair value are however excluded from the requirements of the update. A portfolio segment is defined as the level at which an entity develops and documents a systematic method for determining its allowance for credit losses. As such, segments may consist of types of receivables, industry sectors, risk ratings or other groupings. Classes of financing receivables are a further disaggregation of portfolio segments. When defining classes, consideration should first be given to the initial measurement attribute of the financing receivables such as amortized cost or receivables purchased with credit impairment and accounted for under ASC Consideration should next be given to how management further disaggregates the portfolio when assessing and monitoring risk and performance.

5 ASU What is a credit quality indicator? How can I get a good idea of what is required by the ASU and what the new disclosures may look like? How do the requirements of the new ASU compare with IFRS? When will I be required to comply with the new requirements? A credit quality indicator is a description about the credit quality of a portfolio and could include such indicators as consumer credit risk scores, credit-ratingagency ratings, internal credit risk grades, loan-to-value ratios, and collection experience. The ASU contains example disclosures ( , paragraphs 7 to 12). Appendix B to this paper has similar illustrations. The required disclosures are similar, but not identical, to those required by IFRS 7, Financial Instruments: Disclosures. However, the scope of IFRS 7 includes all financial instruments, not just financing receivables. FASB and the IASB currently have a joint project underway on accounting for financial instruments, including disclosures. Public entities will be required to provide disclosures as of the end of a reporting period beginning with interim and annual reporting periods ending on or after December 15, Disclosures about activity that occurs during a reporting period will be required for interim and annual reporting periods beginning on or after December 15, Nonpublic entities will be required to provide the disclosures for annual reporting periods ending on or after December 15, 2011.

6 6 ASU Appendix B: Sample Disclosures Allowance for Credit Losses and Recorded Investment in Financing Receivables For the Year Ended December31, 20X1 Commercial Real Estate Consumer Residential Finance Leases Unallocated Total Commercial Allowance for credit losses: Beginning Balance $2,000 $7,000 $200 $4,000 $500 $800 $14,500 Charge-offs (1,000) (3,000) (100) (7,000) (300) (100) (11,500) Recoveries - 1, ,610 Provisions 2,000 1, ,000 1, ,400 Ending balance $3,000 $6,000 $910 $5,500 $1,300 $1,300 $18,010 Ending balance: individually evaluated for impairment $1,000 $3,000 $0 $500 $0 $0 $4,500 Ending balance: collectively evaluated for impairment $2,000 $3,000 $910 $4,500 $1,300 $1,300 $13,010 Ending balance: loans acquired with deteriorated credit quality $0 $0 $0 $500 $0 $0 $500 Financing receivables: Ending balance $70,000 $130,000 $20,000 $99,000 $18,000 $337,000 Ending balance: individually evaluated for impairment $12,000 $30,000 $0 $2,000 $0 $44,000 Ending balance: collectively evaluated for impairment $58,000 $100,000 $20,000 $97,000 $18,000 $293,000 Ending balance: loans acquired with deteriorated credit quality $0 $0 $0 $4,000 $0 $4,000 Commercial Credit Exposure Credit Risk Profile by Internally Assigned Grade Credit Quality Indicators As of December 31, 20X1 and 20X0 Commercial Real Estate Commercial Real Estate Commercial Construction Other 20X1 20X0 20X1 20X0 20X1 20X0 Pass $50,000 $52,000 $3,000 $7,000 $60,000 $65,000 Special Mention 8,000 10,000 10,000 12,000 34,000 30,000 Substandard 8,000 6,000 10,000 8,000 4,000 2,000 Doubtful 4,000 5,000 7,000 6,000 2,000 4,000 Total $70,000 $73,000 $30,000 $33,000 $100,000 $101,000 Consumer Credit Exposure Credit Risk Profile by Internally Assigned Grade Residential - Prime Residential - Subprime 20X1 20X0 20X1 20X0 Grade: Pass $68,000 $70,000 $1,000 $1,800 Special mention 12,000 15,000 5,000 7,000 Substandard 10,000 12,000 3,000 5,000 Total $90,000 $97,000 $9,000 $13,800 Consumer Credit Exposure Credit Risk Profile Based on Payment Activity Consumer - Credit Card Consumer - Other Finance Leases Consumer - Auto 20X1 20X0 20X1 20X0 20X1 20X0 20X1 20X0 Performing $ 7,000 $ 7,500 $ 2,500 $ 3,000 $ 16,000 $ 17,000 $ 5,000 $ 3,000 Nonperforming 3,000 1, ,000 1,000 2,000 1,000 Total $ 10,000 $ 8,500 $ 3,000 $ 3,000 $ 18,000 $ 18,000 $ 7,000 $ 4,000

7 ASU Impaired Loans For the Year Ended December 31, 20X1 Unpaid Average Interest Recorded Principal Related Recorded Income Investment Balance Allowance Investment Recognized With no related allowance recorded: Commercial $4,000 $5,000 - $5,000 $100 Commercial real estate Residential - subprime With an allowance recorded: Commercial real estate - construction 17,000 20,000 3,000 20,000 - Commercial real estate - other 2,000 4,000 1,000 1,000 - Residential - subprime 2,000 4, ,000 - Total: Commercial $ 23,000 $ 29,000 $ 4,000 $ 26,000 $ 100 Consumer $ - $ - - $ - $ - Residential $ 2,000 $ 4,000 $ 500 $ 3,000 $ - Modifications As of December 31, 20X1 Number of Contracts Pre-Modification Outstanding Recorded Investments Post-Modification Outstanding Recorded Investments Troubled Debt Restructuring Commercial Residential - subprime 5 10 $ $ 3,500 3,000 $ $ 3,000 2,700 Troubled Debt Restructuring That Subsequently Defaulted Commercial Residential - subprime Number of Contracts 1 7 Recorded Investment $780 $2,000 Age Analysis of Past Due Financing Receivables As of December 31, 20X1 Recorded Greater Total Investment > Days Days than Total Financing 90 Days and Past Due Past Due 90 Days Past Due Current Receivables Accruing Commercial $1,500 $500 $3,000 $5,000 $65,000 $70,000 $0 Commercial real estate: Commercial real estate - construction 1,000 1,400 12,000 14,400 15,600 30,000 - Commercial real estate - other 2,000 3,000 2,000 7,000 93, , Consumer: - Consumer - credit card 800 1,000 3,000 4,800 5,200 10,000 - Consumer - other ,350 3,000 - Consumer - auto 1, ,000 3,500 3,500 7,000 - Residential: - Residential - prime 1, ,500 5,200 84,800 90,000 3,000 Residential - subprime 2,000 2,000 1,000 5,000 4,000 9,000 - Finance leases 1,500 1,800 2,000 5,300 12,700 18,000 - Total $11,050 $10,800 $29,000 $50,850 $286,150 $337,000 $3,500 Note: comparative disclosures showing reporting periods ending before the adoption date are encouraged but not required.

8 8 ASU Appendix C: Supplemental Disclosure Checklist Credit Quality of Financing Receivables Allowance for Credit Losses Disclosure Requirement Summary of Significant Accounting Policies 1. The summary of significant accounting policies shall include the following (ASC ): The basis for accounting for loans and trade receivables The method used in determining the lower of cost or fair value of nonmortgage loans held for sale (that is, aggregate or individual asset basis) The classification and method of accounting for interest-only strips, loans, other receivables, or retained interests in securitizations that can be contractually prepaid, or otherwise settled in a way that the holder would not recover substantially all of its recorded investment. The method of recognizing interest income on loan and trade receivables, including a statement about the entity s policy for treatment of related fees and costs, including the method of amortizing net deferred fees or costs. 2. An entity s summary of significant accounting policies for financing receivables should include all of the following (ASC ): The policy for placing financing receivables on nonaccrual status (or discontinuing accrual of interest) The policy for recording payments received on nonaccrual financing receivables (i.e., as interest income or as a reduction of the principal balance) The policy for resuming accrual of interest The policy for determining past due or delinquency status Existing,, or Applicability Applies to loans and trade receivables. quality and accounted for under ASC With the exception of certain receivables measured at fair value or lower of cost or fair value and trade accounts receivable with a contractual maturity of one year or less that arose from the sale of a good or service, this information now must be provided by class of financing receivable.

9 ASU Disclosure Requirement 3. Policy for charging off uncollectible trade accounts receivable that have a contractual maturity of one year or less and arose from the sale of goods or services (ASC a). 4. A description of the accounting policies and methodology the entity used to estimate its liability for off-balance-sheet credit exposures and related charges for those credit exposures. The description should identify the factors that influenced management s judgment and discussion of risk elements relevant to particular categories of financial instruments (ASC ). General 5. If major categories of loans or trade receivables are not presented separately in the balance sheet, they shall be presented in the notes to the financial statements (ASC ). 6. The allowance for credit losses and, as applicable, any unearned income, any unamortized premiums or discounts, and any net unamortized deferred fees and costs, shall be disclosed in the financial statements (ASC ). Nonaccrual and Past Due Financing Receivables 7. The recorded investment in financing receivables on nonaccrual status, by class of financing receivable (ASC a). Existing,, or Existing Existing Applicability Applies to trade accounts receivable excluding credit card receivables. Off-balance sheet credit exposures, which refers to credit exposures on off-balance sheet loan commitments, standby letters of credit, financial guarantees, and other similar instruments, except for instruments within the scope of ASC 815. Applies to loans and trade receivables. Applies to loans and trade receivables. quality and accounted for under ASC With the exception of certain receivables measured at fair value or lower of cost or fair value and trade accounts receivable with a contractual maturity of one year or less that arose from the sale of goods or services, the disclosure requirement has been expanded to require the disaggregation of nonaccrual financing receivables by class.

10 10 ASU Disclosure Requirement 8. The recorded investment in financing receivables past due 90 days or more and still accruing, by class of financing receivable (ASC b). 9. An analysis of the age of the recorded investment in financing receivables at the end of the reporting period that are past due, as determined by the entity s policy (ASC A). This disclosure is required to be provided by class of financing receivable. Allowance for Credit losses 10. A description of the entity s accounting policies and methodology used to estimate the allowance for credit losses by portfolio segment, including all of the following (ASC Ba): a. A description of the factors that influenced management s judgment, including historical losses and existing economic conditions. b. A discussion of risk characteristics relevant to each portfolio segment. c. Identification of any changes to the entity s accounting policies or methodology from the prior period and the entity s rationale for the change. 11. A description by portfolio segment of the policy for charging off uncollectible financing receivables (ASC Bb). Existing,, or Applicability quality and accounted for under ASC With the exception of certain receivables measured at fair value or lower of cost or fair value and trade accounts receivable with a contractual maturity of one year or less that arose from the sale of goods or services, the disclosure requirement has been expanded to require the disaggregation of nonaccrual financing receivables by class. quality and accounted for under ASC ; certain receivables measured at fair value or lower of cost or fair value; and trade accounts receivable with a contractual maturity of one year or less that arose from the sale of goods or services.

11 ASU Disclosure Requirement 12. The activity in the allowance for credit losses for each portfolio segment for each period, including all of the following (ASC Bc): a. The balance in the allowance at the beginning and end of each period b. Current period provision c. Direct write-downs charged against the allowance d. Recoveries of amounts previously charged off 13. The quantitative effect by portfolio segment of changes to the entity s accounting policies or methodology from the prior period on the current period provision for credit losses (ASC Bd). 14. The amount of any significant purchases of financing receivables during each reporting period, by portfolio segment (ASC Be). 15. The amount of any significant sales of financing receivables or reclassifications of financing receivables to held for sale during each reporting period (ASC Bf). 16. The balance in the allowance for credit losses at the end of each period disaggregated on the basis of the entity s impairment method, by portfolio segment (ASC Bg). To disaggregate on the basis of impairment methodology, an entity shall separately disclose the following amounts: a. Amounts collectively evaluated for impairment (determined under Subtopic ) b. Amounts individually evaluated for impairment (determined under Section ) c. Amounts related to loans acquired with deteriorated credit quality (determined under Subtopic ). Existing,, or Applicability

12 12 ASU Disclosure Requirement 17. The recorded investment in financing receivables at the end of each period related to each balance in the allowance for credit losses, disaggregated on the basis of the entity s impairment methodology (ASC Bh). Impaired Loans 18. For each class of financing receivable (ASC A): a. The accounting for impaired loans b. The amount of impaired loans 19. As of the date of each statement of financial position presented, the recorded investment in the impaired loans, by class of financing receivable, and both of the following: a. The amount of that recorded investment for which there is a related allowance for credit losses determined in accordance with Section and the amount of that allowance. b. The amount of that recorded investment for which there is no related allowance for credit losses determined in accordance with Section As of the date of each statement of financial position presented, the total unpaid principal balance of the impaired loans, by class of financing receivable (ASC a4). 21. The financial institution s accounting policy for recognizing interest income on impaired loans, including how cash receipts are recorded (ASC b) 22. For each period for which results of operations are presented, disclose the following information by class of financing receivable i : a. The average recorded investment in the impaired loans b. The related amount of interest income recognized during the time within that period that the loans were impaired c. The amount of interest income recognized using a cash-basis method of accounting during the time within that period that the loans were impaired, if practicable (ASC c). Existing,, or Existing Applicability Applies to impaired loans. Applies to impaired loans. Applies to impaired loans. Applies to impaired loans. Applies to impaired loans.

13 ASU Disclosure Requirement 23. The financial institution s policy by class of financing receivable for determining which loans the entity assesses for impairment under Section (ASC d). i Existing,, or Applies to loans. 24. The factors considered by class of financing receivable in determining Applies to loans. that the loan is impaired (ASC e). i Credit Quality Information 25. For each class of financing receivable, provide a description of the credit quality indicator ii (ASC a). 26. For each class of financing receivable, disclose the recorded investment in financing receivables by credit quality indicator (ASC b). 27. For each credit quality indicator, the date or range of dates in which the information was updated for that credit quality indicator (ASC c). 28. If an entity discloses internal risk ratings, then the entity shall provide qualitative information on how those internal risk ratings relate to the likelihood of loss (ASC ). Troubled Debt Restructurings The following information should be disclosed for each period for which a statement of income is presented: 29. By class of financing receivable, qualitative and quantitative information, including both of the following (ASC a): a. How the financing receivables were modified b. The financial effects of the modifications Applicability value or lower of cost or fair value and trade accounts that arose from the sale of goods or services. value or lower of cost or fair value and trade accounts that arose from the sale of goods or services. value or lower of cost or fair value and trade accounts that arose from the sale of goods or services. value or lower of cost or fair value and trade accounts that arose from the sale of goods or services. quality and accounted for under ASC ; certain receivables measured at fair value or lower of cost or fair value; and trade accounts receivable with a contractual maturity of one year or less that arose from the sale of goods or services.

14 14 ASU By portfolio segment, qualitative information about how such modifications are factored into the determination of the allowance for credit losses (ASC b). quality and accounted for under ASC ; certain receivables measured at fair value or lower of cost or fair value; and trade accounts receivable with a contractual maturity of one year or less that arose from the sale of goods or services. The following information should be disclosed for troubled debt restructurings (TDRs) where there has been a re-default during the period presented: 31. By class of financing receivable, qualitative and quantitative information about those defaulted financing receivables, including both: a. The types of financing receivables that defaulted b. The amount of financing receivables that defaulted 32. By portfolio segment, qualitative information about how such defaults are factored into the determination of the allowance for credit losses. quality and accounted for under ASC ; certain receivables measured at fair value or lower of cost or fair value; and trade accounts receivable with a contractual maturity of one year or less that arose from the sale of goods or services. quality and accounted for under ASC ; certain receivables measured at fair value or lower of cost or fair value; and trade accounts receivable with a contractual maturity of one year or less that arose from the sale of goods or services. i These disclosures shall be provided for impaired loans that have been charged off partially. Loans that have been fully charged off would have a recorded investment and allowance of zero. ii ASC 310 defines a credit quality indicator as a statistic about the credit quality of financing receivables. Examples of credit quality indicators include all of the following: consumer credit scores, credit-rating-agency ratings, an entity s internal credit risk grades, loan-to-value ratios, collateral, collection experience, and other internal metrics. An entity should use judgment in determining the appropriate credit quality indicator for each class of financing receivables.