Elections required for LIBOR-based hedging relationships

Jan 25, 2021
Audit Financial reporting Reference rate reform Derivatives & hedging

As noted in our white paper, Optional accounting expedients can make LIBOR transition easier, the London Interbank Offered Rate (LIBOR), is expected to be eliminated beginning as early as the end of 2021. Topic 848, Reference Rate Reform, of the Accounting Standards Codification (ASC) provides temporary optional expedients and exceptions to the guidance related to contract modifications, hedge accounting and other transactions to ease the expected burden on financial reporting related to the upcoming phase-out of LIBOR. While certain expedients do not come into play until contracts are modified to replace LIBOR, other expedients may be relevant now to entities that hedge LIBOR-based debt instruments, including the election described in Section F.5.1 of the whitepaper, “Probability of the hedged forecasted transaction.” By making this election now, an entity that is hedging LIBOR-based interest payments can continue to assert that the hedged forecasted transactions remain probable under ASC 848-50-25-2, even though the reference rate for the interest payments is expected to be modified, as long as the hedged interest payments otherwise remain probable of occurring. Careful consideration should be given to this and other relevant elections to ensure they are made and documented on a timely basis, and disclosed in the 2020 financial statements as relevant.