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GASB 31

GASB 31

TECHNICAL REPORT FOR LOGIC

from Patterson & Associates

Accounting Background

The Government Accounting Standards Board, GASB, issued its Statement 31 entitled Accounting and Financial Reporting for Certain Investments and for External Pools in March 1997. The Statement is effective for fiscal years beginning af ter June 15, 1997. New reporting standards and accounting procedures are defined by the Statement as well as a separate reporting standard for external investment pools.

The ownership of the funds involved defines these two types of investment pools (or portfolios). Internal pools are defined as portfolios where all the investments belong to one governmental entity. There would be no cash or as sets from other governmental entities in such an internal pool. Funds from different sources belonging to that entity may be commingled in the pool however. Examples of such an internal pool would be an investment portfolio of a single city, county, sch ool district or authority. (Such a pool would be analogous to the "pooled fund group" defined under the Public Funds Investment Act in Texas.)

External pools contain funds from different governmental entities and earnings are allocated to the individual accounts of the various participants. An external pool is sponsored and managed by a private or governmental entity w ith cash assets from other legally separate entities. The sponsoring entity has the fiduciary responsibility to manage the pool in accordance with its stated investment policy. Examples of external pools include countywide or statewide investment pools.

Both types of pools are being required to report fair market value on all investments over specific maturity limits. Internal pools are required to report fair value on investments which, when purchased, have a maturity longer t han one year. External pools must report fair value on maturities longer than ninety (90) days at purchase. External pools have other specific requirements for disclosure and net asset valuation that do not apply to internal pools. LOGIC is prep ared to report on all the GASB requirements. This report is to assist its participants in accounting for any separate investments they may own outside the LOG IC pool.

Amortized Cost Methodology

Most accounting for investments follows the amortized cost methodology. With this method investment income was reported on an accrual basis as coupon income was received. The premium paid for securities over par (100) would be amo rtized equally over the life of the bond. The amortization for the period was subtracted from the beginning amortized cost to report the ending amortized cost or invested principal. If the security were bought at a discount, the discount would be accret ed over the life of the bond. The accretion for the period was added to the beginning period accredited principal to report the accredited (or amortized) cost or invested principal. This process is applied each reporting period to adjust the amortized v alue (book value) so that at maturity the invested principal (book value) equals the par value. Interest earnings under this methodology are accrued for each reporting period and adjusted by the amortization/accretion of the same period. This method allo ws the investor to accurately reflect the value at which the entity owned the security. This value could be compared to the current market value (the value at which the security could be sold in the open market) to determine an unrealized gain or loss position. This value tells the investor how the portfolio is performing at that point in time and what the portfolio is worth on the open market.

When the security matures there is no gain or loss. All the discount or premium has been amortized over the life of the security.

If a security is sold before maturity, the difference between the amortized book value and the sale proceeds (market value) represent the realized gains or losses. The realized gains or losses are netted into the total earnings for the period.

 

For example, a $1,000,000 bond with a coupon of 5% is purchased at 102 ($1,020,000) with four years to maturity. The premium of $20,000 would be amortized on a daily basis and total $5,000 each year. The 5% coupon would generate $50,0 00 each year in accrued interest (interest earnings). The earnings would be reduced by the effect of the amortization.

BeginningEndingAdj
YrCost BalAm/AccBook ValueInterestAm/AccEarn.
1st1,020,0005,0001,015,00050,000-5,00045,000
2nd1,015,0005,0001,015,00050,000-5,00045,000
3rd1,010,0005,0001,015,00050,000-5,00045,000
4th1,005,0005,0001,015,00050,000-5,00045,000
Mat. 1,000,000200,000-20,000180,000

The amortization reduces the net earnings from each year from $50,000 to $45,000. (The $5,000 is treated as a return of capital each year.)

This amortized value methodology served two functions. In an actively traded portfolio or trading situation the sale decision could be made dependent upon the unrealized gain/losses on the security. A gain on the security would produc e a capital gain to the portfolio. In a buy and hold portfolio in which the governmental entity had bought the security to match a defined cash flow requirement, the amortized cost method provides an accurate measure of the invested principal as the prin cipal moves toward maturity.

(Mortgaged backed securities do not fit this rigid standard because the paydowns on the security as mortgage payments are made may fluctuate throughout the life of the bond. ---------------------)

Market Background

Over the past decade governmental entities have realized the value of their invested assets. They began to see the investment portfolios as an important source of incremental income. As a result, portfolios started to take advanta ge of extended maturities and lower marginally credit risks to increase yield. Since the markets only pay investors for risk taken this means that they were absorbing more risk for additional income. Unrealized gains and losses could act as a caution fl ag that too much risk was being taken by the portfolio in extended maturities or lower credit ratings.

When interest rates changed dramatically in 1994, many governmental investors were forced to sell securities which had unrealized losses thus incurring realized losses. If the entity did not report the portfolio based on amortiz ed cost methodology and consistently compare their book value to the market value (pricing) the governing boards were faced unexpectedly with true losses of principal. Governing boards and state legislatures suddenly demanded a reporting which clearly id entified risks through a comparison of book and market values.

[Losses had also been incurred in the private sector and the Financial Accounting Standards Board issued FASB 115, which required that investments be identified as buy and hold or trading securities. A buy and hold securi ty could be reported on an amortized value but those in the trading category had to be marked to market (compared to the market value) to identify risks. FASB 124 which applies to non-profit organizations, such as universities and foundations, required m ore stringent market value reporting on all investments because of the nature of the funds involved.]

The GASB 31 process is seen as an investment performance - or risk - indicator as much as an investment accounting methodology. It is similar to the performance measurements used by longer bond fund and private investment managers to d etermine the success in their choice of securities and their management of those securities on an ongoing basis. A significant unrealized loss or gain also indicates something about how much risk is present. However, it must be remembered that these man aged longer portfolios are, by their nature, usually more actively managed and not necessarily used for matching cash flow but rather long-term investment income and performance. (This difference between the two is also exemplified in the use of yield ve rsus rate of return because the inflows and outflows of cash interfere with the accurate calculation of rate of return.)

New Investment Definitions

Investment Income

As seen in the example above, investment earnings under the amortized cost method represent the true interest received minus the pro rated amortization or accretion. Under the fair value GASB standard however there are two p arts to the income. (1) The investment income is defined as the accrued interest from the coupon in the reporting period (2) plus or minus the change in the fair value from the beginning of the period. This means that the change in fair value fro m the beginning to end of the period will be shown as income and reported in the financial operating statements. These two components can be combined or reported separately. Given the unrealized nature of this change in value it would serve every government to report these two components separately so that unrealized (i.e. non-existent) income is not interpreted incorrectly and spent when it does not exist!

For example,

The 5% bond from the example above has a beginning fair value on year #1 of 101.00 or $1,010,000. It earns interest during the year of $50,000. At the end of year #1 its market value has fallen to 99.00 or $990,000. The interest for the year is:

Interest$  50,000
Change in fair value$<20,000>
Interest Earnings$  30,000

This component of the unrealized change in value is now captured as investment earnings and reported in the financial statements. This is very different from the amortized cost valuation methodology because under that met hodology no loss would be recognized unless the security was sold before maturity.

The differences between these two methodologies becomes even clearer if we compare the two using the example above at each year-end.

 Amortized Fair ValueChange inAnnual
 Cost Bal.PriceBalanceFair ValueDifference
1st1,020,0001011,010,000 < 10,000 >
2nd1,015,000 99990,000<,000 ><,000 >
3rd1,010,0001011,010,00020,000 0-
4th1,005,000 99990,000< 20,000 >< 15,000 >
 < 20,000 >< 50,000 >

Over the life of the bond the net change in fair value has resulted in a loss in interest earnings of $20,000 on the financial statements even though the security matured and there was no actual loss in interest earnings at all.

Realized Gains and Losses

One of the most important changes under the GASB Statement has to do with the realized gains and losses. Under the amortized cost method, realized gains and losses are added to the investment income for the reporting period. Un der GASB 31, the reporting of gains and losses is optional. If they are reported it is only in the footnotes of the financial statements!

For example, if a $100,000 par bond was carried at fair value at $120,000 and it was sold for $110,000 under the amortized cost method it would result in a $10,000 gain. However, the change in the fair value ($120,000-110,000) would re sult in a loss of $10,000. The -$10,000 is the total contribution of the sale to the investment income for the year. The realized gain of $10,000 can only appear in the notes. When a capital gain/loss transaction occurs (investment sale, call or mat urity), only the change in fair value of the current period is included in investment income. MENTION TWO SETS OF BOOKS HERE For this reason it is important for you to calculate and monitor realized gains/losses on an amortized cost basis also t o assure that real losses do not go undetected.

Fair Value

GASB 31 requires that any security in an internal investment pool purchased with maturity greater than one year be reported at fair value in the financial statements. Fair value is defined as the market value (bid) if the security is traded on a recognized exchange or the value of the investment in a current transaction with a qualified buyer not under the condition of a forced sale. GASB did not take a position as to whether the bid or asked price should be used. H owever, the Board does expect that if a security is bought at an asked price and prices do not change then the ask should be used for consistency. This does not recognize the realities of the market where prices are constantly changing. If accuracy is r equired the bid price should be used since that is the price at which the security could be sold on the open market.

Money market investment with maturity of one year or less at the time of purchase may be carried at amortized cost. Money market securities are defined as short term, liquid securities including US Treasury Bills and Notes, commercial paper, banker's acceptances, and agency discount notes and notes. The funds invested with investment pools that operate like a money market fund ("2a-7 like pools") such as LOGIC are also reported at cost. Your investment in LOGIC wo uld always be carried at par (100). A "2a-7 like pool" is a reference to the SEC's rule 2a-7 in the Investment Company Act of 1940 that allows money market funds to use amortized cost rather than market value. This is because of the short- term nature of the securities (no longer than 13 months) and the little inherent volatility of such securities and because they maintain a $1 (not $2) net asset value.

In either of these cases, the securities that have a maturity longer than one year when purchased (which we will call GASB specific securities) must always be reported at fair value even when they have less than a year remaining to maturity. They will continue at fair value until matured or liquidated.

All asset-backed securities (ABS), derivatives (floating notes, step-ups, ???????????? DID THEY EXCEPT CALLABLES????? callables, etc.) and structured notes are to be reported at fair value regardless of the time to maturity. Investmen t in open end mutual fund or pools with fluctuating net asset value (such as Lone Star Liquidity Plus or the Government Fund) must be reported at fair value based on the published share price and number of shares held because of the increased risk these p ools and funds represent to the investor. GASB has new reporting standards for government sponsored external pools that are not "2a-7 like".

Exceptions to Fair Value Reporting

GASB intended that most investments be reported at fair value. However, because of the relative short-term nature of most governmental portfolios there are certain exceptions noted in the statement.

(1) Money market investments purchased with less than one year to maturity may be carried at amortized cost. These securities such as Treasury Bills and Notes, commercial paper, banker's acceptances and agency discount notes and notes are short term and not very volatile. The spread (or difference) between the bid and asked prices is very narrow which indicates little volatility and a better ability for the investor to liquidate near his/her cost if necessary. For that reason GASB al lowed that these could be carried at amortized cost.

(2) Non-negotiable certificates of deposit are also carried at amortized cost (which will always be 100). The statement specifies that "nonparticipating contracts" are to be so carried. "Nonparticipating" includes those securities whose value is not affected by changes in the market or interest rates. These are non-negotiable and non-transferable. In addition, the statement adds that the fair value can not be impaired by the credit of the issuer. Section 8 appe ars to provide for CDs up to $100,000 to be carried at original cost, but does not limit the maturity to one year.

Investment Reporting

To illustrate how the GASB reporting methodology is to work we will use the example of fair value securities from the GASB 31 Statement, Appendix C. The Appendix traces five securities over a two-year period. Three securities are held at the beginning of the period, two additional bonds are purchased and finally three of the securities are sold during the two-year period. (The amortized value is not shown in these examples.)

Year One Beginning Positions (July 1, 1997)

BondCouponOriginal Cost or
Amortized Cost
Year End
Par Value
Year End
Fair Value
18.00%100,000100,000100,000
25.50%520,000500,000540,000
36.50%200,000200,000240,000
 Totals820,000800,000880,000

 

Purchases and Sales During 1st Fiscal Year

 

During the first year the following sale and purchase took place:

TransactionBondCoupon Par ValueTranaction
Value
Transaction
Date
Sale36.50%200,000250,00012/31/97*
Purchase46.00%300,000330,00012/31/97*
Assuming the purchase and sale are at the end of the interest period for simplicity

Bond #3 had a fair value at the beginning of the period of $240,000 and is sold for $250,000 generating a $10,000 increase in fair value. The change in fair value at year end will be the net increase or decrease of sale proceed s less beginning fair value ($250,000-240,000 or $10,000)

Bond #4 is purchased for $330,000 which is its fair value for the period until it is marked to market at the end of the period. The beginning fair value for securities purchased throughout the year is its original purchase cost regardl ess of how the market has moved.

End of Year Positions and Fair Value Reporting (June 30, 1998)

 

Bond

Cpn

(Col A)

Beg Yr Fair Value

(Col B)

Purchases

(Col C)

Sales

(Col D)

FY1 End Fair Value

(Col E)

Change in Fair Value

1

8.00%

100,000

   

120,000

20,000

2

5.50%

540,000

   

510,000

-30,000

3

6.50%

250,000

 

250,000

0

10,000

4

6.00%

0

330,000

 

315,000

-15,000

 

Total

880,000

330,000

250,000

945,000

-15,000

The change in fair value is summarized as:
 

FY1 Ending Fiscal year Fair Value

945,000

(Col D)

 

Add: Proceeds of Sales

250,000

(Col C)

 

Less: Cost of Purchases

-330,000

(Col B)

 

Less: FY1 Beginning Fiscal Year Fair Value

-880,000

(Col A)

 

Change in Fair Value

- 15,000

 

 

This decrease in fair value of - $15,000 is required by GASB to be included in investment earnings.

Earning Accruals

Since the change in fair value represents only one of the components in GASB reporting we must also look at the interest accrued during the period. The accrued earnings would be reported in a manner as shown below.

For Fiscal Year 1 (7/1/97-6/30/98)

Bond

Cpn

Par

Annual Earnings

Days Held

Investment Earnings

Closing Position

1

8.00%

100,000

8,000

360

8,000

Hold

2

5.50%

500,000

27,500

360

27,000

Hold

3

6.50%

200,000

13,000

180

6,500

Sold 12/31/97

4

6.00%

300,000

18,000

180

9,000

Purchased 12/31/97

   

Total Accrued Earnings for the Period

   

51,000

 
   

Plus: Increase(Decrease) in Fair Value

   

-15,000

 
   

Total Investment Earnings

   

36,000

 

Purchases and Sales During 2nd Fiscal Year

The following transactions are assumed to have occurred during the second fiscal year (7/1/98 to 6/30/99).

Transaction

Bond

Coupon

Par Value

Transaction

Value

Transaction

Date

Sale

1

8.00%

100,000

110,000

09/30/98

Sale

4

6.00%

300,000

330,000

09/30/98

Purchase

5

6.00%

300,000

310,000

09/30/98

End of 2nd Year Positions and Fair Value Reporting (June 30, 1999)

Bond

Cpn

(Col A)

Beg Yr Fair Value

(Col B)

Purchases

(Col C)

Sales

(Col D)

FY1 End Fair Value

(Col E )

Change in Fair Value

             

1

8.00%

120,000

 

110,000

0

-10,000

2

5.50%

510,000

   

550,000

40,000

4

6.00%

315,000

 

330,000

0

15,000

5

6.00%

0

310,000

 

300,000

-10,000

   

945,000

310,000

440,000

850,000

35,000

The change in fair value is summarized as:

 
 

FY2 Ending Fiscal year Fair Value

850,000

(Col D)

 

Add: Proceeds of Sales

440,000

(Col C)

 

Less: Cost of Purchases

-310,000

(Col B)

 

Less: FY1 Beginning Fiscal Year Fair Value

-945,000

(Col A)

 

Change in Fair Value

35,000

 

This increase in fair value of $35,000 is required by GASB to be included in investment earnings.

The change in fair value is stated separately for each reporting period in the life of a security. (Prepare for a very long spreadsheet!)

For Fiscal Year 2 (7/1/98-6/30/99)

Bond

Cpn

Par

Annual

Earnings

Days

Held

Investment

Earnings

Closing

Position

1

8.00%

100,000

8,000

90

2,000

Sold 09/30/98

2

5.50%

500,000

27,500

360

27,500

Hold

4

6.00%

300,000

18,000

90

4,500

Sold 09/30/98

5

6.00%

300,000

18,000

270

13,500

Purchased 09/30/98

   

Total Accrued Earnings for the Period

   

47.500

 
   

Plus: Increase(Decrease) in Fair Value

   

35,000

 
   

Total Investment Earnings

   

82,500

 

Making the Move to Fair Value Reporting in FY 97-98

The GASB Statement becomes effective for all governmental entities for fiscal years beginning after June 30, 1997. Therefore provision must be made now to establish the fair value for all "qualified investments" at fiscal yea r end. This valuation will become the Beginning Fiscal Year Fair Value for 1996-97.

It is very important to establish accurate market values for all investments at your fiscal year end. You should also identify how your values were established for disclosure purposes. The statement requires the following disclosures:

  1. The methods and assumptions used to estimate fair value, if that fair value is based on other than quoted market prices.
  2. The policy for determining which investments are reported at amortized cost.
  3. For investment in non-SEC registered external pools, a description of regulatory oversight and whether fair value of the entity's position is the same as the share value. (LOGIC will provide you the statement to use in your statements for this pur pose.)
  4. Any involuntary participation in an external pool.
  5. If information is not available from an external pool, the methods and assumptions used to determine fair value.
  6. Any income from investments associated with one fund that is assigned to another fund.

The following are steps to follow in preparing for the fair value conversion. Remember that only certain investments are to be included in the fair value reporting. Other investments, such as "2a-7 like" external pools and m oney market securities with less than one year to maturity at purchase, are carried at amortized cost.

Step #1

Identify the investments in your portfolio with maturities longer than one year (365 days) as of June 30, 1997. We will call them GASB specific securities for this purpose. CAN WE TAKE ALL SECURITIES AT THE ADJUSTMENT OR JUST THOSE L ESS THAN A YEAR????

Step #2

Obtain the fair value of the GASB specific securities from a reputable source. You can use the Wall Street Journal closing bid price for June 30, 1997 or have your portfolio marked to market by an independent broker or adviser. (LOGIC and Patterso n & Associates will provide this service to any of its participants if the portfolio is provided 15 days before the fiscal year end.)

Step #3

Compare the market cost to the amortized (or original cost) book value of each GASB specific security. This gives you your unrealized gain/loss on that security.

Step #4

If the fair value is less than the amortized (reported) value, the unrealized loss will be posted to fund balance at the beginning of the new fiscal year. Since the unrealized loss is already posted to fund balance, the unrealized chang e in value will not be reflected in investment income for the 6/30/97 fiscal year or in the New Year. Each will now be individually reported for the New Year.

For example, if the total fair value on the securities is $450,000 and the amortized value is $500,000 the entry for the beginning year for the $50,000 difference would be:

 
 

Debit

Credit

Description

Investment Assets

 

50,000

GASB 31 Transition

Fund Balance

50,000

 

GASB 31 Transition

Step #5

If the fair value is greater than the amortized (reported) value, the unrealized gain will be posted to fund balance at the beginning of the new fiscal year. Since the unrealized gain is already posted to fund balance, the unrealized c hange in value will not be reflected in investment income for the 6/30/97 fiscal year or in the New Year. Each will now be individually reported for the New Year. For example, if the total fair value on the securities is $500,000 and the amortized value is $450,000 the entry for the beginning year for the $50,000 difference would be:

 
 

Debit

Credit

Description

Investment Assets

50,000

 

GASB 31 Transition

Fund Balance

 

50,000

GASB 31 Transition

Step #6

Report the other exempted investments (non-GASB specific securities) such as securities with less than one year to maturity at purchase at amortized cost.

Step #7

As mentioned above, the reporting on realized gains and losses is optional in the notes of the financial statements; however, once realized gains/losses are recognized, two additional disclosure statements are required in the footnotes:

"a) The calculation of realized gains and losses is independent of a calculation of the net change in the fair value of investments."

"b) Realized gains and losses on investments that have been held during more than one fiscal year, and sold in the current year, were included as a change in the fair value of the investments reported in the prior year(s) and the c urrent year."

Complying with GASB 31 and State Laws

Many states have statutes, which require amortized book reporting. This was adopted to insure that entities knew the value of their portfolios in the real marketplace should liquidation become necessary for cash flow purposes. As ment ioned above, it also was established to indicate unacceptable levels of risk in the case of portfolios that had been extended. Longer maturities accept more volatility risk and are paid for that risk by higher yields. A portfolio which is significantly o utperforming comparable indices (such as the Treasury Yield Curve) would indicate that some additional degree of risk is being absorbed. Portfolios that are significantly under-performing may indicate that the portfolio is too short and not using accepta ble risk levels.

For this reason, it is important for investors and oversight committees to look at several key indicators on a periodic basis.

Because GASB 31 can distort the true amortized value of a security, and a security under GASB reporting can actually be in a loss position versus cash and show a gain - or the reverse situation, it might be recommended that every entity maintain and report on both an amortized cost basis and the GASB basis.

There is a danger that investors will be forced, by GASB 31 reporting requirements, to avoid unrealized losses and in turn actually incur realized losses on their portfolio or take GASB gains to improve the statements without a true rea lized gain. A quick turn in market conditions could show a security which has been bought for a specific purpose (for example a debt service payment) at a gain (market less than fair value). The security would normally be considered a buy and hold posit ion for the upcoming payment and have a good market level coupon. Reacting to GASB requirements the investment manager may be forced or convinced to "window dress" the portfolio by selling the security to recognize the GASB gain and have to rei nvest in a lower interest rate security. For situations such as this, it is vitally important for the investment manager and the oversight boards to understand the ramifications of investment decisions and the impetus to liquidate securities unnec essarily.

Remember that GASB 31 is required for annual financial statement purposes only. Monthly and quarterly reports can be produced on an amortized cost basis as is required in Texas under the Public Funds Investment Act as well as in many o ther states. This will undoubtedly require additional work for the investing entity not using only a pool, but, the accuracy of the information and the accuracy with which risk can be assessed are vital to every governmental entity. Changes to your Inve stment Policy may be necessary also to assure that the objectives of the portfolio and the reporting on that portfolio are clear.

If you have comments or questions to share on the GASB 31 Statement please send them to LOGIC or to Patterson & Associates.

LOGIC
1201 Elm Street
Suite 3500
Dallas, Texas 75270
 
800-TX-LOGIC
internet: www
e-mail:
Patterson & Associates
301 Congress Avenue
Suite 570
Austin, Texas 78704
 
800-817-2442
Internet: www.patterson.net
e-mail:
linda@patterson.net
 

The mailing address for GASB is:
GASB
401 Merritt 7
P.O. Box 5116
Norwalk, CT 06856-5116
 
203-847-0700
internet:
http://www.financenet.gov/gasb.htm
email: director@gasb.org

To order a copy of GASB 31
203-847-0700, Ext. 10
Request Product Code GS31
Cost is $10.50


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