Financial Reporting and Regulatory Update

Third Quarter 2021

Effective dates for all GASB statements

GASB statement

Effective dates – reporting periods beginning after


Early adoption

Postponement of the Effective Dates of Certain Authoritative Guidance (GASB Statement 95)

Postpones the effective dates of certain provisions in statements and implementation guides that first became effective or are scheduled to become effective for periods beginning after June 15, 2018, and later.
Upon issuance, May 8, 2020 Not applicable

Fiduciary Activities (GASB Statement 84)

Improves guidance regarding the identification of fiduciary activities for accounting and financial reporting purposes and how those activities should be reported. Establishes criteria for identifying fiduciary activities of all state and local governments and clarifies whether and how business-type activities should report their fiduciary activities.

Establishes criteria for identifying fiduciary activities of all state and local governments focused on 1) whether a government is controlling the assets of the fiduciary activity and 2) the beneficiaries with whom a fiduciary relationship exists. Separate criteria are included to identify fiduciary component units and postemployment benefit arrangements that are fiduciary activities.

Dec. 15, 2019


Majority Equity Interests (GASB Statement 90)

Revises and clarifies the guidance for reporting a government’s majority equity interest in a legally separate organization and improves the relevance of financial statement information for certain component units.

Dec. 15, 2019


Replacement of Interbank Offered Rates (GASB Statement 93)

Addresses accounting and financial reporting implications that result from the replacement of an interbank offered rate (IBOR), most notably the London Interbank Offered Rate (LIBOR), which is expected to cease to exist in its current form at the end of 2021, prompting governments to amend or replace financial instruments tied to LIBOR.

June 15, 2020, except:

Paragraph 11b, periods ending after Dec. 15, 2021

Paragraphs 13 & 14, June 15, 2021

Accounting for Interest Cost Incurred Before the End of a Construction Period (GASB Statement 89)

Supersedes guidance set forth in Statement 62, “Codification of Accounting and Financial Reporting Guidance Contained in Pre-November 30, 1989 FASB and AICPA Pronouncements,” which generally required capitalization of interest cost incurred before the end of a construction period. Statement 89 requires that interest cost incurred before the end of a construction period be recognized as an expense in the period in which the cost is incurred for financial statements prepared using the economic resources measurement focus and not be included in the historical cost of a capital asset reported in a business-type activity or enterprise fund.
Dec. 15, 2020 Permitted


(GASB Statement 87)

Revises recognition and measurement for lease contracts by lessors and lessees by requiring recognition of certain lease assets and liabilities for leases that previously were classified as operating leases and as inflows of resources or outflows of resources recognized based on the payment provisions of the contract. Establishes a single model for lease accounting based on the foundational principle that leases are financings of the right to use an underlying asset.

June 15, 2021


Omnibus 2020

(GASB Statement 92)

Addresses a variety of topics including the effective date of Statement 87 and Implementation Guide No. 2019-3 for interim financial reports; reporting of intra-entity transfers of assets between a primary government employer and a component unit defined benefit pension plan or defined benefit other postemployment benefit (OPEB) plan; the applicability of Statements 73 and 74 to reporting assets accumulated for postemployment benefits (PEBs); the applicability of certain requirements of Statement 84 to postemployment benefit arrangements; measurement of liabilities (and assets, if any) related to asset retirement obligations (AROs) in a government acquisition; reporting by public entity risk pools for amounts that are recoverable from reinsurers or excess insurers; reference to nonrecurring fair value measurements of assets or liabilities in authoritative literature; and terminology used to refer to derivative instruments.

Varies by issue (see pages 5 and 6 of the statement and page 2 of statement 95)

Upon issuance, Feb. 5, 2020

June 15, 2021


Permitted by topic

Certain Component Unit Criteria, and Accounting and Financial Reporting for Internal Revenue Code Section 457 Deferred Compensation Plans

(GASB Statement 97)

Clarifies how the absence of a governing board should be considered in determining whether a primary government is financially accountable for purposes of evaluating potential component units and modifies the applicability of certain component unit criteria as they relate to defined contribution pension and OPEB plans, and other employee benefit plans (for example, certain Section 457 plans). Establishes accounting and financial reporting requirements for Section 457 plans that meet the definition of a pension plan and for benefits provided through those plans.

Varies by issue (see pages 4 and 5 of the statement)

Upon issuance, June 23, 2020

June 15, 2021

Permitted by topic

Conduit Debt Obligations (GASB Statement 91)

Clarifies the definition of a conduit obligation and stipulates that a conduit debt obligation is a liability of the third-party obligor, not the issuer, thus eliminating the option for government issuers to recognize a conduit debt obligation as a liability. Establishes standards for accounting and financial reporting of additional commitments extended by issuers and arrangements associated with conduit debt obligations and improves required note disclosures.

Dec. 15, 2021


Public-Private and Public-Public Partnerships and Availability Payment Arrangements 

(GASB Statement 94)

Provides guidance for public-private and public-public partnership arrangements (PPPs), including those that are outside of the scope of the GASB’s existing guidance for those transactions – namely Statement 60, “Accounting and Financial Reporting for Service Concession Arrangements,” and Statement 87, “Leases.” The statement also makes certain improvements to the guidance previously included in Statement 60 and provides accounting and financial reporting guidance for availability payment arrangements (APAs).  

June 15, 2022


Subscription-Based Information Technology Arrangements (GASB Statement 96)

Provides guidance on the accounting and financial reporting for subscription-based information technology arrangements (SBITAs) for governments. Defines a SBITA; establishes that a SBITA results in a right-to-use subscription asset – an intangible asset – and a corresponding subscription liability; provides the capitalization criteria for outlays other than subscription payments, including implementation costs of a SBITA; and requires note disclosures regarding a SBITA.
June 15, 2022 Permitted