GASB Statement No. 61, The Financial
Reporting Entity: Omnibus
An Amendment of GASB Statements No. 14 and No. 34
Presented by
Andrew Richards, CPA, Partner Christopher Telli, CPA, Senior Manager November 13, 2012
GASB 61, The Financial Reporting Entity
Purpose & Objective
• Amends GASB Statement 14 & 34 to improve
financial reporting for a governmental financial
reporting entity
• Clarifies/Amends
o
Financial Accountability Concept
o“Misleading to Exclude” criteria
oBlending criteria
o
Reporting of equity interest in legally separate
GASB 61, The Financial Reporting Entity
Purpose & Objective
• Improves guidance relating to component units & equity
interest transactions, making financial statements more
relevant
• Allows users to better assess accountability of elected
officials
• Improves focus of the financial reporting entity on the
primary government & allows for better distinction of
primary government (PG) & component unit (CU)
• Helps ensure PG doesn’t understate financial position for
equity interests
5
• Provisions of this Statement are effective for
financial statements for periods beginning after
June 15, 2012
o
Earlier application is encouraged
GASB 61, The Financial Reporting Entity
Effective Date
• Primary governments
• Stand-alone governments
• Separately issued financial statements of
governmental components
• Nongovernmental component units when included
in a governmental financial reporting entity
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Scope
•
Component unit: Legally separate organizations for
which elected officials of the primary government
are financially accountable. In addition, a
component unit can be another organization for
which the nature and significance of its relationship
with a primary government is such that exclusion
would cause the reporting entity's financial
statements to be misleading
⁰
Can be governmental organization, nonprofit of
for-profit corporation
GASB 61, The Financial Reporting Entity
Component Unit Definition
• GASB 14 requires inclusion of a legally separate
entity if it’s fiscally dependent on the primary
government
o
GASB 61 amends this to ALSO require a financial benefit or
burden relationship, in addition to being fiscally
dependent
o
If the financial accountability concept is met, the
organization should be reported as part of the primary
government’s financial reporting entity
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GASB 61, The Financial Reporting Entity
Amended Inclusion Criteria
GASB 61, The Financial Reporting Entity
Amended Inclusion Criteria
• Fiscally dependent: A government that cannot do one or
more of the following without the substantive approval of
another government: (a) determine and modify its budget,
(b) levy taxes or set rates or charges, or (c) issue bonded debt
• A financial benefit or burden relationship exists if the
primary government is
o
Legally entitled to or can access the organization’s resources
o
Legally obligated or has otherwise assumed the obligation to finance
deficits of, or provide financial support to the organization
Amended Inclusion Criteria
• The primary government is financially accountable if
it appoints voting majority of the organization’s
governing board &
1.
It is able to impose its will on the organization, OR
2.
There is potential for the organization to provide specific
financial benefit to, or burden on, the primary
government
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• Primary government may be financially accountable
for a fiscally dependent government even if that
government has a:
1)
Separately elected governing board (elected school
board but fiscally dependent on local government)
2)
Governing board appointed by a higher level of
government (school board appointed by State
officials but fiscally dependent on local government)
3)
Jointly appointed board (board appointed jointly by
several local governments but fiscally dependent on
one)
GASB 61, The Financial Reporting Entity
Amended Inclusion Criteria
Question #1
It is possible for a component unit of a municipality to
be which of the following
a) another governmental organization
b) a for-profit corporation
c) a not-for-profit corporation
d) all of the above
e) Not sure
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• Potential for dual inclusion
o
Organization could meet financial accountability criteria
for one primary government, but fiscally dependent on
another
o
Can only be component unit in one reporting entity
oRequires careful judgment
o
Generally, fiscal dependency will govern, but not always
GASB 61, The Financial Reporting Entity
Amended Inclusion Criteria
• Paragraphs 12, 20, 39 and 66 of Statement 14
allowed for legally separate entities to be included as
component units, even if they do not meet criteria
for inclusion, if exclusion would make the financial
statements misleading or incomplete
• GASB 61 eliminates “incomplete” & amends GASB 14
to clarify the manner in which “misleading to
exclude” provisions should be applied in making this
determination
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“Misleading to Exclude” Criterion
• For organizations not meeting the financial
accountability criteria
o
Management may include if professional judgment
determines exclusion is misleading
o
Determinations based on nature & significance of
organization’s relationship to primary government
o
Should be applied for all separately issued financial
statements
GASB 61, The Financial Reporting Entity
“Misleading to Exclude” Criterion
• GASB 61 further clarifies what types of relationships
should be considered when determining if
misleading to exclude
o
Closely related or financially integrated
Closely related: Focus on financial relationships
Financially integrated: Documented through policies, practices or
organizational documents of either primary government or the
organization being evaluated
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GASB 61, The Financial Reporting Entity
“Misleading to Exclude” Criterion
• Clarifies types of relationships that affect the
determination of major component units
• Eliminates requirement to consider each component
unit’s significance relative to other component units
• Requires consideration of nature and significance of
relationship to primary government
o
Services provided
oTransactions
o
Significant burden or benefit relationship
GASB 61, The Financial Reporting Entity
Major Component Unit Requirement
• Presentation & reporting requirements
o
Major component unit reporting requires one of the
following
Presenting each major component unit in a separate column in
the reporting entity’s statements of net assets & activities
Combining statements of major component units in reporting
entity’s basic financial statements after the fund financial
statements, or
Presenting condensed financial statements in notes
o
Nonmajor component units should be aggregated in a
single column
o
Combining statements allowed but not required
19Major Component Unit Requirement
Question #2
An organization is included with a primary government’s
reporting entity if that organization is fiscally dependent
AND
a) A potential financial benefit or burden relationship
exists
b) The primary government appoints all of the board
members
c) The entity is not a component unit of another
government
d) the entity has a derivative instrument
e) Not sure
• Amends paragraph 53 of Statement No. 14 to
include additional provision when governing bodies
are substantively the same
• Adds provision for component units whose total
debt outstanding is expected to be repaid entirely or
almost entirely with resources from primary
government
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GASB 61, The Financial Reporting Entity
Blending Criteria
GASB 61, The Financial Reporting Entity
Blending Criteria
• Substantively the same
o
Sufficient representation of primary government’s entire
governing body on the component unit’s governing body
so decisions of the primary government cannot be
overridden by component units
o
Happens when primary government’s board is essentially
the same as component unit’s board
o
Example: city redevelopment authority is comprised
• Blending method should be used when governing
bodies substantively the same
&
o
There is financial benefit or burden relationship
OR
o
Management of the primary government has
operational responsibility for component unit
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Blending Criteria
GASB 61, The Financial Reporting Entity
Blending Criteria
• Operational responsibility
o
Management in this context are people below the
governing board
Responsible for day-to-day operation
o
Achieved if management manages activities of the
component unit in essentially the same manner in which it
manages its own programs, departments or agencies
• Blending method should also be used if
o
Services provided by component unit are
entirely, or almost
entirely, to primary government or exclusively, or almost
exclusively, benefits primary government
Similar to internal service funds
oRequirement still met if
Services provided to others are insignificant to overall activities of
component unit
Services are provided indirectly to primary government (i.e. to
employees)
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GASB 61, The Financial Reporting Entity
Blending Criteria
• Blending also required for component units whose
total debt outstanding, including leases, is expected
to be repaid entirely, or almost entirely, with
resources of primary government
o
New Requirement
o
Repayment generally occurs through continuing pledge &
appropriation by the primary government to component
unit
GASB 61, The Financial Reporting Entity
Blending Criteria
• Reporting blended component units
o
Statement clarifies that funds of a blended component
unit have the same financial reporting requirements as a
fund of primary government
Included as part of primary government’s other funds in fund
statements &/or combining statements
General fund of blended component unit is still reported as a
special revenue fund
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Blending Criteria – Reporting
Question #3
Major component units should be determined based
on:
a) The component unit's significance to other
component units
b) The component unit's total assets
c) The component unit's total net assets
d) The component unit's significance to the primary
government
GASB 61, The Financial Reporting Entity
Blending Criteria – Reporting
• Business-type activities
o
Business-type activity (BTA) that reports in a single column may
blend component unit into single column
Present condensed combining information in notes
Condensed information should include (minimum)
Condensed statement of net assets
Condensed statement of revenues, expenditures & changes in net assets Condensed statement of cash flows
o
May also show blended component unit in separate column &
combining primary government total column
o
Multi-column BTA may add additional columns as if fund of
primary government
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• The Statement clarifies reporting of equity interests
in legally separate organizations
o
Primary government should report an asset for its equity
interest in a discretely presented component unit
If government’s intent is to directly enhance its ability to
provide governmental services, it should be discretely
presented as a component unit
If government’s intent is to obtain income or profit, it should
report equity as investment
o
Minority interest in joint ventures are shown in net assets
as “restricted, nonexpendable”
GASB 61, The Financial Reporting Entity
• Clarifies that governments should disclose the
rationale for including each component unit &
manner in which it is included
• Additionally, notes should include
o
Brief description of the component unit and its
relationship to primary government
o
If component unit is discretely presented, blended or
included in the fiduciary fund financial statements
o
How separate financial statements for component
units may be obtained
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Amendments to Note Disclosures
GASB 61, The Financial Reporting Entity
Amendments to Note Disclosures
• Notes essential to fair presentation in reporting
entity’s basis financial statements include
o
Governmental & business-type activities, major funds,
nonmajor funds, including blended component units
o
Major discretely presented component units (DPCU)
• Selected DPCU disclosures throughout notes
o
Use professional judgment
GASB 61, The Financial Reporting Entity
Impact
• Expected some component units may no longer
meet inclusion criteria under new Standard
• Not expecting the reverse
• All component units will need reevaluation by
primary government
• Blending must be reevaluated under new criteria
o
If no longer meets requirements to blend, then discretely
presented (de-blended)
• Change in reporting entity will result in restatement
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Question #4
The blending criteria of GASB 61 is met if the governing
bodies are substantively the same and
a) A financial benefit or burden relationship exists
b) The entities are financially integrated
c) The financial statements are not otherwise
incomplete
d) It's based solely on professional judgment
e) Not sure
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Transition
• In first period applied, treated as adjustment of prior
periods & restatement of all prior periods
• If restatement is not practical, cumulative effect
should be reported as a restatement of beginning
net assets (or fund equity or fund balance, as
appropriate) for earliest period restated
• Financial statements should disclose nature of
restatement & its effect
GASB 61, The Financial Reporting Entity
Examples
All examples taken from GASB 2011-12 Comprehensive
Implementation Guide
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GASB 61, The Financial Reporting Entity
Examples – Case 6
Case 6 – Board of Education with Appointed Members
Facts: Local boards of education are created as bodies corporate. The county board of commissioners
appoints members of the board of education for municipalities located within the county, but may remove members only for cause. The local boards of education select their own management and control their own day-to-day operations.
State law gives the state legislature the responsibility for providing a uniform system of free public schools. Accordingly, the state grants the county the following budgetary authority:
Local school boards submit their entire budget to the county commissioners.
The county commissioners make appropriations to the local boards of education for that portion of the budget that is to be funded by the county.
The county commissioners approve the local school boards' budgets, which are then adopted by the local school boards.
If the county board allocates funds specifically to certain purposes or functions, the local boards of education are permitted to change the appropriation for the intended program or purpose within certain limits.
Changes in the school budget resolution, whether increases or decreases to projects in (1) acquisition of land or (2) building acquisition and construction, require county commissioner approval.
Examples – Case 6 (cont.)
Case 6 – Board of Education with Appointed Members (cont.)
The county may allocate part or all of each appropriation by purpose, function or project. The authority of the county is limited by a statutory requirement that the county provide adequate school facilities. However, the county has no authority over the administration of the construction. A local board of education has legal recourse if it feels that the county is not providing adequate facilities or is not fulfilling its statutory funding responsibilities. A clerk of court or a judge can order a county to increase its financial support of a local board of education.
Conclusion: The local board of education would be discretely presented as a component unit of
the county. The county board of commissioners appoints the members of each local board of education and is able to impose its will through its budgetary authority, which grants the county approval authority over the entire budget and thus is not merely a compliance approval required as a condition to receive financial aid. In addition, the county commissioners have approval authority over the capital acquisitions of the local board of education.
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GASB 61, The Financial Reporting Entity
Examples – Case 6a
Case 6a – Board of Education with Elected Members
Facts: Consider the same facts as in Case 6, except that the members of the local
board of education are separately elected.
Conclusion: If the members of the local board of education are separately elected,
the board of education would be evaluated as a component unit of the counties
county based on the fiscal dependency criteria, which include the financial benefit or
burden criteria. The board of education is fiscally dependent on the county based on
the county’s budgetary approval authority. In addition, the local board of education
imposes a financial burden because the county provides resources for its operations.
The board should be reported as a discretely presented component unit.
GASB 61, The Financial Reporting Entity
Examples – Case 13
Case 13 – Library Association
Facts: A library association is a body corporate and politic. It is governed by a fourteen-member board,
serving staggered seven-year terms.
Seven of the fourteen members are direct appointees of the town.
The remaining seven members are elected by the other board members. (Vacancies are filled by a majority vote of the remaining thirteen members, seven of whom—a voting majority—are direct appointees of the town.)
The town may not remove the members of the library's board, except for cause. The town has no authority over the budget of the association; however, the town provides funding for approximately 90% of the library's funding for library operations. The library also receives donations and does a substantial amount of fund raising to finance capital improvements. The library board controls the management of the library's day-to-day operations and holds property in its own name.
Conclusion: The library would be reported as a discretely presented component unit of the town. All of
the library board members are either appointed directly by the town or selected by a group that is controlled by appointees, which means that the town does appoint a voting majority of the board. The funding provided by the town for the library's operations imposes a financial burden on the town.
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GASB 61, The Financial Reporting Entity
Examples – Case 13a
Case 13a – Library Association
Facts: Consider the same facts as in Case 13, except that the
two boards are substantively the same and the library
association is managed in the same manner as a department of
the town.
Conclusion: The library would be reported as a blended
component unit of the town because the two boards are
substantively the same and management of the town has
operational responsibility for the component unit.
Examples – Case 21
Case 21 – Art Foundation
Facts: The Carol Sauer Art Foundation was established as a legally separate, tax-exempt organization to
support fine arts in the greater Anytown metro area. The foundation has a history of providing substantial financial support to several different entities each year including XYZ Art Museum, Anytown’s public museum; community theatre groups; and other organizations with objectives consistent with the foundation’s charter. Occasionally, donations received by the foundation are restricted for the benefit of specific organizations, but generally, restricted donations are distributed currently, rather than held. An accumulation of restricted resources would not be significant to any of the designated beneficiaries. The support given to XYZ Art Museum during the current year was significant to the museum. However, depending on the ongoing needs of other qualifying organizations and the foundation’s resources available for distribution, this level of support to the museum has varied considerably over the years.
Conclusion: The Carol Sauer Art Foundation is not required to be reported as a component unit of XYZ Art
Museum because at least one of the three criteria is not satisfied. The “direct benefit” criterion is not met because the foundation supports several other organizations, and the resources it receives and holds are not entirely or almost entirely restricted for the benefit of XYZ Art Museum. Because the first criterion is not met, neither the “entitlement/ability to access” criterion nor the “significance” criterion needs to be considered. However, the “incomplete or misleading to exclude” concept in paragraph 41 of Statement 14, as amended, should be considered.
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Andrew Richards, CPA | Partner | 501.372.1040 | [email protected]
Christopher Telli, CPA | Senior Manager | 719.471.4290 | [email protected]
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