The SEC’s Division of Economic and Risk Analysis (DERA) has observed that some filers are not appropriately tagging disclosures about their finance lease liability, undiscounted future lease payments, and the excess amount of the undiscounted future lease payments over the finance lease liability (for example, imputed interest). DERA is providing guidance to filers to address some of this mistakes.
When tagging these disclosures, filers should use the following elements from the US GAAP Financial Reporting Taxonomy (GRT):
- FinanceLeaseLiability
- FinanceLeaseLiabilityPaymentsDue
- FinanceLeaseLiabilityUndiscountedExcessAmount
The majority of tagging errors observed include:
- inappropriate use of custom tags to tag the excess amount of the undiscounted future lease payments over the finance lease liability
- incorrect use of negative values to tag the excess amount as an offset to the undiscounted future lease payments
- use of incorrect tags related to capital leases under the Financial Accounting Standards Board (FASB) Accounting Standards Codification (ASC) 840 – Leases, which has been superseded by ASC 842 – Leases
Custom tags accommodate special circumstances in a filer’s particular disclosure. However, the SEC has recognized that the use of custom tags could potentially inhibit users’ ability to compare similar information across companies. For more related information, refer to Release No. 33-9002 (January 2009). The SEC’s rules designate that electronic filers are required to create and use a new special element given that an appropriate tag does not exist in the standard list of tags for reasons other than or in addition to an inappropriate standard label.
Concerning negative values, the majority of XBRL numeric elements are designed to be entered as positive values even if they are generally considered as offsets to other values. In particular, accrued depreciation, depletion, and amortization for property plant and equipment should be entered as positive values. Refer to sections 6.6.30 and 6.11.6 of the EDGAR Filer Manual (Volume II) for more information on negative values.
Choosing current and relevant elements from the GRT to tag disclosures allows for more effective access to and analysis of investor disclosures, other market participants and other data users. When in the process of selecting, filers should thoroughly evaluate the accounting standards disclosure requirements and the GRT prior to mapping their disclosures to the taxonomy elements.
Filers may refer to the US GAAP Financial Reporting Taxonomy for additional related information. For more data quality reminders, see Staff Observations and Guidance webpage on the SEC’s website.
Sources:
Tagging for Finance Lease Liability, Future Payments, and the Excess Amount of the Future Payment Over the Finance Lease Liability (sec.gov)