Comments due on FASB Fair Value Disclosures Exposure Draft

September 24, 2009

The Financial Accounting Standards Board (FASB) Exposure Draft of a proposed Accounting Standards Update seeks to improve disclosures about fair value measurements. The proposed update would apply to independent institutions with alternative investments and other assets with significant unobservable - or level 3 - inputs. Comments are due October 12, 2009.

The proposed Update, "Fair Value Measurements and Disclosures," will affect topic 820 in the new FASB Codification, which was originally issued as FASB Statement No. 157, "Fair Value Measurements." Because assets recorded at fair value that use level 3 inputs are thought to have greater degrees of value subjectivity and uncertainty, the proposed update would require disclosure of much more information about such assets.

The proposal would require the following types of additional disclosures:

The effect of reasonably possible alternatives for the level 3 inputs used
Amounts of significant transfers in or out of level 1 and level 2 categories of fair value measurements and the reason for the transfer
Activity in level 3 fair value measurement that includes gross purchase, sale, issuance, and settlement information by asset class
Disclosures about inputs and valuation techniques for all fair value measurements that use level 2 or level 3 inputs

The proposal defines asset class as detail that comprises a financial statement line item. Independent institutions and not-for-profit foundations affiliated with public institutions would have to disclose activity, transfers between level 1 and level 2 input categories, and valuation technique information by investment type. Because valuations for levels 2 and 3 use and weigh various matters and issues to produce fair value, disclosures could be extensive.

Comments are due to FASB by October 12, 2009. NACUBO urges the many institutions and foundations affected by this proposal to send comments either directly to FASB or to NACUBO for inclusion in the industry response.