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Displaying
the Funding Status of Postretirement Plans
The Impact of SFAS 158 Disclosure
By David
N. Hurtt, Jerry G. Kreuze, and Sheldon A. Langsam
JULY 2007 -
FASB issued Statement of Financial Accounting Standards (SFAS) 158,
Employers’ Accounting for Defined Benefit Pension and
Other Postretirement Plans, in September 2006. SFAS 158 represents
the initial phase of a comprehensive project on employers’
accounting for postretirement plans. FASB began the project in November
2005 in response to requests by users of financial statements, the
SEC staff, members of FASB’s Financial Accounting Standards
Advisory Council and User Advisory Council, and representatives
of the Pension Benefit Guaranty Corporation. Its goal is to improve
transparency and understandability regarding the costs and obligations
of providing postretirement benefits and the ability of an entity
to fulfill its obligations under its pension plans. FASB believes
this project is important due to the magnitude and long-term nature
of existing arrangements, in spite of the declining trend of companies
sponsoring defined benefit postretirement plans. Specifically,
SFAS 158 requires employers to fully recognize their obligations
associated with their defined pension, retiree healthcare, and
other postretirement plans in their financial statements. A company
must recognize in its statement of financial position the overfunded
or underfunded status of a defined benefit postretirement plan,
measured as the difference between the fair value of plan assets
and the benefit obligation. The measurement date for determining
funding status must coincide with the date of the employer’s
statement of financial position. The
impact on the statement of financial position may be significant,
but because most changes will be recognized as a component of
other comprehensive income, net of tax, the income statement should
not change much. All public, nonpublic, and not-for-profit organizations
are affected by SFAS 158.
Reasons
for Plan Accounting Changes
FASB cited
numerous reasons for mandating changes in pension and other postretirement
plan accounting. FASB believes that SFAS 158 will provide financial
statements that are more complete and easier to understand. Existing
standards on pension and postretirement plans, according to FASB,
fail to produce representationally faithful and understandable
financial statements, by allowing employers to recognize an asset
on the statement of financial position for plans that are significantly
underfunded. Although SFAS 87 mandates minimum liability recognition,
that measurement is based on the accumulated benefit obligation.
Furthermore, under certain circumstances SFAS 106 does not require
the recognition of a minimum liability.
FASB believes
that disclosure of the underfunded status of defined benefit postretirement
plans in the footnotes, as currently presented, is not a substitute
for proper recognition of this funding status in the statement
of financial position, causing users difficulty in assessing an
employer’s financial position and its ability to satisfy
plan obligations. Moreover,
the actuarial gains and losses and the prior service costs and
credits that arise during the period, according to FASB, should
be recognized as a component of other comprehensive income, net
of tax. Deficiencies in present reporting, according to FASB,
could result in an inefficient allocation of resources in the
capital markets.
FASB also
maintains that financial reporting will be improved by measuring
plan assets and benefit obligations as of the same date as the
employer’s other assets and liabilities. Present alternative
measurement dates add complexity and reduce understandability.
They allow potentially significant changes in plan assets and
benefit obligations that occur after the measurement date but
before the fiscal year-end to go unrecognized until the following
period.
Specifics
of SFAS 158
The basic
approach to measuring plan assets, benefit obligations, or net
periodic benefit cost is not changed by SFAS 158. It does, however,
require entities to report the overfunded or underfunded status
of defined benefit postretirement plans in their statement of
financial position. The funding status is measured as the difference
between the fair value of plan assets and the benefit obligation.
The benefit obligation for pension plans is calculated as the
projected benefit obligation, while for other postretirement benefit
plans, such as a retiree healthcare plan, it is calculated as
the accumulated postretirement benefit obligation. When computing
the (present value of the) benefit obligation, employers should
consider rates of return on high-quality fixed-income investments.
These assumed discount rates should be reevaluated at each measurement
date.
For presentation
on the statement of financial position, the aggregate statuses
of all overfunded plans are recognized as an asset, while the
aggregate statuses of all underfunded plans are recognized as
a liability. Employers presenting a classified statement of financial
position should separately report the current and noncurrent portions
of the asset or liability in accordance with existing standards.
SFAS 158 does not allow entities to aggregate all plans and report
the net amount as a single net asset or net liability. The netting
of all plans, according to FASB, is inconsistent with other standards
that preclude offsetting assets and liabilities unless a right
of offset exists.
The funding-status
determination must coincide with the date of the employer’s
statement of financial position for fiscal years ending after
December 15, 2008. Previously, under SFAS 87, the measurement
date for the pension plan could be up to three months earlier
than the date of the employer’s statement of financial position.
The measurement date conformity should not be applied retrospectively.
An exception to this rule applies if the plan is sponsored by
a subsidiary that is consolidated using a different fiscal period
than the parent, pursuant to ARB 51, Consolidated Financial
Statements. In that case, the date used to consolidate the
subsidiary’s statement of financial position should be used
for the postretirement benefit plan assets and benefit obligations.
Actuarial
gains and losses and the prior service costs and credits that
arise during the period that are not recognized as components
of net periodic benefit cost (pursuant to SFAS 87 and 106) will
be recognized as a component of comprehensive income, net of tax.
As these gains, losses, costs, and credits are subsequently recognized
as components of net periodic benefit cost, accumulated other
comprehensive income will be adjusted accordingly. In determining
the applicable income tax effects, the provisions of SFAS 109
shall be followed.
Any transition
asset or obligation remaining from the initial application of
SFAS 87 or 106 shall be recognized as an adjustment to the opening
balance of retained earnings, net of tax. These amounts would
not be subsequently amortized as a component of net periodic benefit
cost.
In addition
to recognizing the funding status of a plan in the statement of
financial position, employers must disclose the following:
- For each
period a statement of income is presented, the net actuarial
gain or loss and the prior service cost or credit must be recognized
in other comprehensive income, separated into amounts initially
recognized in other comprehensive income and amounts subsequently
recognized as adjustments to other comprehensive income, as
those amounts are included as components of net periodic benefit
cost.
- For each
period a statement of financial position is presented, the amount
of net actuarial gain or loss and the prior service cost and
credit must be included in accumulated other comprehensive income.
- An estimate
of the net actuarial gain/loss and the prior service cost/credit
included in accumulated other comprehensive income that will
be recognized as a component of net periodic benefit cost over
the next fiscal year must be presented.
By reporting
the funding status of the defined benefit postretirement plan
in the statement of financial position, certain existing disclosures
are eliminated. Current disclosures to reconcile the funded status
of the plan to amounts recognized in the employer’s statement
of financial position are eliminated, as are disclosures that
reference the additional minimum pension liability. Because the
measurement date of the plan conforms with the financial statements,
there is no need to report the measurement date of the plan.
SFAS 158
applies to public, nonpublic, and not-for-profit organizations,
with an effective date for fiscal years ending after December
15, 2006, for public companies, and for fiscal years ending after
December 15, 2007, for all other entities. Earlier application
is encouraged. All requirements of SFAS 158 should be applied
retrospectively for all financial statements presented, unless
it is impracticable to do so. A single transition method must
be applied consistently for all of an employer’s defined
benefit plans. Plan assets and benefit obligations do not have
to be remeasured for interim-period reporting.
Implementation
Issues
Based on
input from constituents, FASB maintains that the costs of implementation
will not be significant. All the information needed to recognize
a plan’s funded status is already determined and included
in annual footnote disclosures. Minimal costs should be incurred
in reorganizing the information from the footnotes to the financial
statements.
Costs will
be incurred, however, by companies that previously used an earlier
measurement date for determining plan assets and benefit obligations,
and thus must now align the plan measurement date with the date
of the employer’s statement of financial position. These
costs may include fees paid to external consultants to measure
benefit obligations, value plan assets, and change systems and
processes for accumulated information, as well as fees paid to
external auditors to audit the results of a second measurement
of plan assets, benefit obligations, and related effects of net
periodic benefit cost.
Reporting
the results of the funded statuses of postretirement plans may
have some economic consequences. Companies with significantly
underfunded plans could have their cost of capital increased due
to changes in behavior of lenders and investors. Employees may
see future benefits decrease as companies try to reduce, eliminate,
or otherwise revise their plans. FASB contends, however, that
the economic nature of plans determines decisions by lenders,
investors, donors, and others, not their financial accounting
treatment. Only time will tell if the reporting of the funding
status of plans will impact employees and the cost of capital,
especially for those companies whose plans are significantly underfunded.
Case
Studies: Financial Statement Impact
SFAS 158
will not impact all companies uniformly. Old industrial companies
with heavily unionized workforces will be most affected. These
companies typically have defined benefit pension and postretirement
plans that are also often underfunded. A recent report by Bear
Stearns found that companies with the biggest balance sheet changes
probably include the likes of General Motors, Verizon, BellSouth,
and General Electric. These four companies were selected to determine
the impact of SFAS 158 on their financial statements.
The 2005
financial statement results for these four companies were modified
to include SFAS 158 implementation as of January 1, 2004. The
impact of the restatements is summarized in Exhibit
1 and then detailed for each company. The changes to their
income statements and statements of comprehensive income are readily
observable from their restated statements of financial position.
The impact on net income is insignificant, as most adjustments
flow through comprehensive income.
Of the four
companies examined, General Electric’s statement of financial
position would be least affected by the provisions of SFAS 158
(Exhibit
2). The funding status of its postretirement plans, under
SFAS 158 treatment, would be overstated on its statement of financial
position by $9.1 billion. Its total assets would be $9.1 billion
less, deferred income taxes would decrease by $1.6 billion, and
stockholders’ equity (specifically, other comprehensive
income) would decrease by $7.5 billion. General Electric’s
debt-to-equity ratio would increase from 508% to 544%, an increase
of 36%, while its debt-to-asset ratio would increase by only 0.9%.
BellSouth’s
postretirement plan funding status would be reduced by $5.3 billion
(Exhibit
3). Its total assets would be $4.5 billion less, liabilities
would fall by $1.1 billion, and stockholders’ equity (retained
earnings of $94 million and other comprehensive income of $3.3
billion) would be $3.4 billion less. BellSouth’s debt- to-equity
ratio would increase by 19%, and its debt-to-asset ratio would
increase by 2.9%.
Verizon’s
financial results would be more significantly impacted (Exhibit
4). Specifically, Verizon’s postretirement plan funding
status on its statement of financial position would be reduced
by $16 billion. Its total assets would be $13 billion fewer, liabilities
would be reduced by $1.9 billion, and shareholders’ equity
(retained earnings of $12 million and other comprehensive income
by $11.2 billion) would be reduced by $11.2 billion. Verizon’s
shareholders’ equity would decrease from $39.7 billion to
$28.4 billion, a 28% decline. The debt-to-equity ratio would increase
significantly, from 256% to 351%. Even before SFAS 158 was issued,
Verizon had frozen its pension benefits for management employees
and announced that new management employees hired after December
31, 2005, were not eligible for pension benefits (instead they
receive an increased company match on their savings plan contributions).
The impact
of SFAS 158 on General Motors far surpasses the impact on the
other companies examined (Exhibit
5). General Motors’ shareholders’ equity would
go from $14.6 billion to negative $38.2 billion—total assets
would be less than total liabilities. The funding status of its
postretirement plans would decrease by $64.4 billion, total assets
would decrease by $16 billion, liabilities would increase by $22.2
billion, and shareholders’ equity would decrease by $38.3
billion (retained earnings by $21 million and other comprehensive
income by $38.2 billion). From a GAAP standpoint, General Motors
has negative equity. Equity may be positive on a fair value basis,
however, as many of General Motors plant assets may be undervalued.
Nevertheless, SFAS 158 requirements do portray General Motors
in a significantly different perspective and add greater transparency
to its underfunded postretirement plan obligations. The magnitude
of General Motors’ promises to its existing employees and
the costs of those present commitments are presented in a more
transparent manner. Whether General Motors can satisfy those future
obligations remains to be seen, however, especially given the
competition in the automobile industry. General Motors will also
incur additional costs to comply with SFAS 158, as its September
30 plan measurement date does not coincide with its December 31
year-end.
A
Significant Step
SFAS 158
mandates recognition of the overfunded or underfunded status of
defined benefit postretirement plans. The plans’ measurement
date must coincide with the date of the statement of financial
position for fiscal years ending after December 15, 2008. Without
a doubt, SFAS 158 will adversely impact the reported financial
results of numerous companies. Industrial companies with many
unionized workers will be the most significantly impacted. These
impacts may cause companies to eliminate, reduce, or modify benefits
to employees. Lenders, investors, donors, and others may view
these postretirement benefit arrangements differently in the wake
of this enhanced transparency.
SFAS 158
will reignite discussions similar to those after the issuance
of SFAS 106. Shareholders will pressure companies to more effectively
manage the postretirement plan commitments. Nonetheless, FASB
believes that SFAS 158 will result in a more complete, comparable,
and representationally faithful presentation of postretirement
benefit plans. The cost of implementation should be minimal, but
the impact on future postretirement plan policies and practices,
cost of capital computations, and labor negotiations may be significant.
What is certain is that, just like SFAS 106, SFAS 158 will be
a significant item of discussion in corporate boardrooms.
David
N. Hurtt, PhD, CPA, CMA, is an associate professor in the
department of accounting and business law, Baylor University, Waco,
Texas.
Jerry G. Kreuze, PhD, CPA, and Sheldon A. Langsam, PhD,
CPA, are both professors in the department of accountancy,
Haworth College of Business, Western Michigan University, Kalamazoo,
Mich.
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