NACUBO Submits Comments on Changes to Fair Value Measurements and Disclosures

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September 8, 2010

In an attempt to align U.S. GAAP and International Financial Reporting Standards (IFRS) with regard to fair value measurements and disclosures, the Financial Accounting Standards Board (FASB) issued for comment an exposure draft (ED) in June 2010. The ED proposes new disclosures requirements which include a measurement uncertainty analysis for recurring Level 3 fair value measurements. This analysis is the most significant of the proposed disclosures, and potentially the most problematic. Organizations would be required to disclose the effects on Level 3 fair value measurements for changes in unobservable inputs when another input could reasonably have been substituted and would have resulted in a significant difference in fair value. The FASB proposed a similar disclosure requirement in an exposure draft issued in 2009, but received numerous comments from respondents expressing concern about the time and effort involved in preparing such disclosures. As a result, the requirement was not included in the Accounting Standards Update as issued.

The ED also addresses the concept of highest and best value, measuring fair value of financial instruments managed within a portfolio on the basis of net exposure to a particular risk, and application of blockage factors and other premiums and discounts in fair value measurements. These proposed changes are not expected to have a significant impact on colleges and universities.

The Accounting Principles Council (APC) of NACUBO has issued a comment letter to the FASB in response to the ED expressing concerns about the measurement uncertainty analysis and the inclusion, in general, of not-for-profit organizations in recently issued and possible future standards.