By Mike Antich
Last week, on Aug. 27, the Securities and Exchange Commission (SEC) raised
the possibility that some U.S.
publicly traded companies will be able to use international accounting standards
(IAS) next year and may require all U.S. companies switch to IAS between 2014-2016. The
SEC commissioners voted unanimously to release the proposal for a 60-day
comment period. If approved, the SEC estimates 110 companies in 30 industries would
be eligible to use IAS for fiscal years ending after Dec. 15, 2009. Only the
top 20 companies in each industry would be eligible, based on market
capitalization and whether their largest foreign competitors use IAS.
Efforts to develop
international accounting standards were started in 1973 by the International Accounting
Standards Board (IASB). Today, nearly 100 countries require or allow companies
to prepare financial statements using IAS. The U.S.
uses Generally Accepted Accounting Principles (GAAP); however, there is a
growing movement for the U.S.
to adopt the IAS rules where there are differences between the two rules. This
process has been called “convergence.” Currently, accounting standards vary between
and countries that use IAS, such as the European Union nations, making comparison
of corporate financial statements difficult. For multinational companies,
compliance with a single set of accounting standards would be a major
improvement to the current multiplicity of national standards and would promise
significant cost savings, among other benefits. These multinationals have told
the SEC that allowing IAS in the U.S. would also bring efficiencies since
many of their non-U.S. subsidiaries already use international accounting standards.
It is estimated that U.S
companies would require two to three years to make the switch to IAS, with
smaller businesses needing more time. The SEC said it would consider requiring
companies to switch to international accounting standards for 2014 financial
statements, with mid-size companies required to switch in 2015, and small companies
to switch in 2016. Under this so-called
“road map,” a final decision on adoption would be made by the SEC in 2011.
IAS Impact on Fleet Leasing in the U.S.
Fleet leasing is one facet of fleet management that will be impacted
by international accounting standards. Lease accounting is governed by
Financial Accounting Standard (FAS) 13 in the U.S. and by IAS 17 elsewhere. One of the main
differences between these two rules is that FAS 13 treats typical open-end
leases as operating (off-balance sheet) leases, while IAS 17 treats them as
capital (on-balance sheet) leases. IAS
17 allows closed-end leases to be treated as operating leases. Currently, the IASB and the U.S. Financial
Accounting Standards Board (FASB) are working on a project – known as the Lease
Accounting for Lessees Project – to align these two rules. “All indications are
that the new rules will require all leases to be capitalized, regardless of
whether they are open- or closed-end. In fact, the SEC has stated that convergence
on such issues is likely to be a ‘gating’ factor to moving to international
accounting standards,” said Dan Frank, vice president and general manager for
Four Wheels at Wheels Inc. “Thus, regardless
of whether companies move to international standards or continue to use U.S.
GAAP, it is probable that all leases will need to be capitalized sometime in
the 2011-2016 timeframe." Exactly how
the leases will be capitalized, including accounting for renewal options, contingent
rents, and residual guarantees, is still open for discussion by the standards
“I think it is highly unlikely the SEC
decision will have any material impact on fleet leasing in the U.S.,”
said Jim Frank, president & CEO of Wheels Inc. “The vast majority of our
clients lease for the financial, administrative, and service benefits a fleet
management company can provide and not merely for off-balance sheet
accounting. The biggest change will be
in the reporting requirements that will be associated with accounting for a
capitalized lease rather than simply an expense. Most lessors should be ready
to assist their clients with this to make it as seamless as possible. Since all leases will ultimately be treated
the same, we don’t expect a large change in demand for open- versus closed-end
George Kilroy, president
& CEO of PHH Arval says the recent SEC decision could impact funding
decisions at some companies. “If early adoption means adopting current IAS 17
lease accounting, it could mean many of the leases in the fleet industry that
are treated as operating leases would have to be capitalized. That may impact
some companies’ decision as to whether to lease or not, or to change lease
structure,” said Kilroy.
Other Considerations and Implications
Many in the fleet industry expect the SEC to endorse IAS 17, but with
modifications that will result from the Lease Accounting for Lessees
There are also other implications to the adoption of
IAS 17. “We’ll have to watch this closely, given the current state of
the credit markets and, for some companies, the growing importance of
financial ratios to their ability to access funds,” said Kilroy.
According to Jim Frank, this issue is likely to be addressed by the enormity of the overall change to IAS. “When companies switch over to international accounting standards, lenders, accountants, analysts, and investors are all going to need to adjust their measurements and ratios to accommodate the new reporting. Many of them already add back the off-balance sheet items today.”
Others view the implications of the convergence between FASB and IASB as still uncertain. “The interpretation of open-end leases will likely change in some form or fashion. Whether these new interpretations will lead some fleets to choose to vary their ownership versus open-end lease versus closed-end lease is unknown,” said Rick Fletcher, strategic marketing manager for GE Capital Solutions Fleet Services. “Financial reporting treatment is only one of many factors to consider when making fleet decisions. The question will become how important operating lease treatment is to companies. In today’s sophisticated financial markets, with increased focus on underwriting standards, off- versus on-balance sheet accounting will likely be viewed similarly by capital markets. Therefore, many believe the impact of the change will be minimal, but only time will tell.”
Wholesale Change to U.S. Accounting Rules
If the international accounting standards are eventually adopted, the result will be wholesale change in U.S. accounting rules. While FASB and IASB are working to bring convergence between accounting rules, there still remain differences between the two.
Not everyone is happy with the possible convergence between FASB and IASB standards. “I do not like the idea of the U.S. losing control over accounting rules because the IASB is not as accessible as the FASB has been to the fleet leasing industry,” said Bill Bosco, president of Leasing 101 in Suffern, N.Y. “IASB has such a vast base of interested parties that it seems they listen to no one, and it seems the political processes around the world have allowed some cases where large, influential companies get special treatment.”
Let me know what you think.