New FASB Standards Codification: Are You Ready? Leveraging Essential and Non-Essential Guidance to Prepare GAAP Statements and Footnotes

Transcription

1 presents New FASB Standards Codification: Are You Ready? Leveraging Essential and Non-Essential Guidance to Prepare GAAP Statements and Footnotes A Live 110-Minute Teleconference/Webinar with Interactive Q&A Today's panel features: Tom Hoey, Project Director, FASB Codification Project, Financial Accounting Standards Board, Norwalk, Conn. Nelson Haight, Shareholder, GBH CPAs PC, Houston Michael Westervelt, Manager, Assurance and Accounting Quality Group, LarsonAllen, Charlotte, N.C. Gordon Weber, Partner, Corporate Group, Faegre & Benson, Minneapolis Wednesday, October 14, 2009 The conference begins at: 1 pm Eastern 12 pm Central 11 am Mountain 10 am Pacific The audio portion of this conference will be accessible by telephone only. Please refer to the dial in instructions ed to registrants to access the audio portion of the conference. CLICK ON EACH FILE IN THE LEFT HAND COLUMN TO SEE INDIVIDUAL PRESENTATIONS. If no column is present: click Bookmarks or Pages on the left side of the window. If no icons are present: Click View, select Navigational Panels, and chose either Bookmarks or Pages. If you need assistance or to register for the audio portion, please call Strafford customer service at ext. 10

2 New FASB Accounting Standards Codification TM : Are You Ready? Webinar Oct. 14, 2009 Explanation Of FASB Codification By Director Of FASB Codification And XBRL Projects Thomas Hoey,, Thomas Hoey & Associates, LLC hoeytj@thoey thoey.com

3 Today s s Agenda Background Overview and timing Why codify? What was codified? How is the Codification structured? How will FASB update the Codification? Walk-through Slide 2

4 Overview Single source of authoritative U.S. GAAP for non- governmental entities in a topically organized format Major restructuring into roughly 90 topics Codifies previous level A-D A D GAAP issued by a standard-setter setter Supersedes previous level a-d a d GAAP issued by a standard setter, except for guidance issued by the SEC Not intended to change U.S. GAAP Eliminates the multiple-tiered tiered U.S. GAAP hierarchy in favor of two levels: authoritative and non-authoritative Any sources of U.S. GAAP not included in the Codification are non-authoritative, except for grandfathered guidance In addition to the Codification content, there is an online Codification Research System designed to improve the usability of authoritative U.S. GAAP Slide 3

5 Timing Authoritative version was made available July 1, 2009 Codification is effective for interim and annual periods ending after Sept. 15, 2009 Slide 4

6 Why Codify? Slide 5

7 Accounting BC (Before Codification) FASB Statements FASB Staff Positions FASB Interpretations Accounting Principles Board Opinions FASB Technical Bulletins AICPA Audit and Accounting Guides Accounting Research Bulletins AICPA Statements of Position EITF Abstracts (and issue summaries) EITF Appendix D AICPA Practice Bulletins FASB Staff Implementation Guidance AICPA Technical Questions and Answers AICPA Audit Risk Alerts FASB Concepts Statements AICPA Accounting Interpretations AICPA Issues Papers SEC S-X Rules SEC S-K Items SEC Speeches Topics Covered SEC SAB Codification Topics SEC ASR / FRR Codification Sections Note: Not all of the above were level A-D GAAP and therefore were not in the FASB Accounting Standards Codification Slide 6

8 Why Codify? Constituent concern that U.S. GAAP was overly confusing and difficult to research Multiple standard-setters, setters, multiple types of standards, multiple indexing schemes, different levels of authority, not integrated, etc. Goal Simplify user access by codifying all authoritative U.S. GAAP in one spot 7

9 Codified Content Addressed in detail in the Notice to Constituents Codification includes Authoritative guidance For example, standards sections, implementation guidance, and so forth Selected portions from Basis for Conclusions AICPA TIS content for Software Revenue Recognition Codification excludes Content deemed redundant or non-authoritative For example, much of basis for conclusions Concept Statements Grandfathered content Certain soon-to to-be superseded content (e.g., FAS 141) Slide 8

10 Codified Content SEC SEC content is the domain of the SEC SEC content included in Codification topics, but in separate SEC sections SEC guidance is required only for SEC registrants Many private companies do not want SEC guidance SEC Material sections include the full text of the relevant guidance Slide 9

11 How Is The Codification Structured? Terminology is important for effective communication Areas: Five groupings of topics General Principles Presentation Financial Statement Accounts Assets, liabilities, equity, revenue, expense Broad Transactions Business combinations, leases, etc. Industry Topics: Broadest categorization of related content Subtopics: Generally distinguished by type or scope Sections: Nature of the content, such as recognition, measurement, disclosure, and so forth Subsections: Allows further segregation and navigation of content Slide 10

12 Example Topic Leases Subtopics Overall Operating Leases Capital Leases Sections Scope Disclosure Scope Disclosure Scope Disclosure Lessees Lessees Lessees Lessees Lessees Lessees Subsections Lessors Lessors Lessors Lessors Lessors Lessors Note: This is for illustration only and does not include all Topics, Subtopics, Sections and Subsections. Slide 11

13 How Will FASB Update The Codification? Through FASB Statement 168, Codification updates integrated standards on an after-the the-fact basis Beginning with the effective date FASB will issue the results of standards activity as an Accounting Standards Update numbered as Year Sequence (such as, ) 05) that includes: Summary and basis for conclusions Codification update instructions The FASB will update the Codification concurrent with the release e of a Accounting Standards Update Proposed Accounting Standards Updates will be exposed with the proposed Codification update instructions The Accounting Standards Updates will not be authoritative in their own right Current and transitional text presented together to ensure access s to all relevant content in the same location Slide 12

14 Walk-Through Slide 13

15 FASB Functionality The functionality demonstrated today is from the FASB Codification Professional View at asc.fasb.org Other access Basic View (free) and Academic Access The best way to gain a good understanding is to take the online tutorial Only 20 minutes (audio, animation, no questions) Important point The FASB licenses the content to various organizations for their research systems Other research systems may not have certain features contained on the Codification web site Slide 14

16 Search Go To Browse Notice to Constituents Tutorial Slide 15

17 How Will Users Locate Previous Standards? Constituents need a means of identifying where previous level a-d a d GAAP resides in the Codification Codification Research System provides a mapping of the previous level a-d a standards to the Codification Cross-reference reference feature Printer-friendly with sources Slide 16

18 Locate Previous Standards: Cross-Reference Feature Slide 17

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20 Locate Previous Standards: Printer-Friendly With Sources Slide 19

21 < Printer Friendly with Sources

22 [EITF D-080, paragraph 1, sequence 62]

23 Some Tips For Users Research Model Broad research - Start by browsing topics, not by searching Consider the nature of the issue and select the related Section Use Table of Contents that vary by content on selected page Section Navigation Section links Join All Sections to view entire Subtopic Locating your Position What Links Here For example, identify all paragraphs related to a transition paragraph agraph Printing Available in page functions Glossary Multiple terms General Notes Fair value option, etc. SEC Material Accounting Standards Updates and Exposure Drafts Slide 22

24 Research Model Broad research Start by browsing topics, not by searching Consider the nature of the issue and then select the related Section Use the Table of Contents to browse the paragraph headings Narrow research Use text search to find specific terms or phrases Slide 23

25 Areas Topics Subtopics Locate the topic and subtopic

26 < Consider the nature of the issue

27 Use Table of Contents to narrow the list

28 Section Navigation: Section Links Slide 27

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30 Section Navigation: Join All Sections Slide 29

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32 Section Navigation: Locating your Position Slide 31

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34 What Links Here Slide 33

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38 Printing: Page Functions Slide 37

39 <

40 Glossary: Multiple Terms Slide 39

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42 DEFINITION 1

43 DEFINITION 2

44 General Notes Slide 43

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48 SEC Material Slide 47

49 48

50 Accounting Standards Updates And Exposure Drafts Slide 49

51 Accounting Standards Updates Exposure Drafts Pre-Codification Standards 50

52 51

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54 Other Related Matters Content Gaps: Authoritative GAAP does not address all GAAP Industries: Contain incremental guidance only FASB will address cases where codification process may have changed GAAP Features Archive: Able to compare versions What s s New: Displays activity by date or topic Annotations: Place personal notes Print FASB plans to issue the Codification in print Slide 53

55 XBRL Taxonomy FASB provided Codification references to XBRL-US. The references were posted in August as an extension file The Codification references are a replacement for the superseded legacy references Codification includes an XBRL Section and shows all XBRL elements related to a paragraph Slide 54

56 New FASB Accounting Standards Codification: Are You Ready? Webinar 1 Oct. 14, 2009 Approaches For Regular Research Nelson Haight, GBH CPAs, PC nhaight@gbhcpas.com

57 What Happened 2 On July 1, 2009, the body of U.S. GAAP literature changed with the Financial Accounting Standards Board s (FASB) release of the Accounting Standards Codification (ASC) The release of the ASC: Simplified and streamlined the body of authoritative U.S. GAAP Did not change U.S. GAAP Did change the way we research, cite and keep current with evolving standards

58 3 Accessing The ASC Access can be found at Two views are available: The Basic view, which is a free view without research tools or other functionality The Professional view, which is a subscription service that provides more functionality and capability, including, among other things, the ability to: Join sections and combine subsections for viewing selected excerpts Cross-reference to legacy standards Additional print functions The following examples assume you have access to more than the Basic view, either through the FASB site or another research tool

59 4 When To Use The ASC When and how to utilize or reference the ASC will depend upon the circumstances Circumstances where accessing the ASC would be appropriate include: Updating an existing footnote for the new references in the ASC after Sept. 15, 2009 Researching the accounting and required disclosures for a new transaction or event Verifying existing disclosures and accounting treatment are current

60 5 Updating Legacy Disclosures For U.S. GAAP References Plain English disclosures are encouraged; however, in some instances, it s easier to reference the U.S. GAAP literature rather than describe the accounting in the footnote For example, EITF 00-19: Accounting for Derivative Financial Instruments indexed to, and Potentially Settled in, a Company s Own Stock, is probably a poor candidate for plain English disclosure, given its complexity In this instance, updating any references to with the new ASC references is probably preferable and easier So, what is the easiest way to do that?

61 6 Updating Legacy Disclosures For U.S. GAAP References (Cont.) Cross-Reference Tool Assuming the literature sited is still applicable, the easiest route is to use the Cross-Reference function, an option available within the ASC Research System as a tab at the home page The Cross-Reference function allows the user to enter the legacy U.S. GAAP reference and function, which will then return the ASC reference information and vice versa Most users will probably utilize the legacy U.S. GAAP reference to ASC reference function See the following example:

62 Updating Legacy Disclosures For U.S. GAAP References (Cont.) 7

63 8 Accounting And Required Disclosures

64 9 Accounting And Required Disclosures (Cont.)

65 10 Accounting And Required Disclosures (Cont.) If you generally know the literature you need to look at, and you know the legacy U.S. GAAP references, the Cross-Reference function previously discussed can also be useful

66 11 Referring Outside The ASC Public companies ASC includes references to some of the SEC rules and staff guidance related to basic financial statements (i.e. Regulation S-X, Financial Reporting Releases, Staff Accounting Bulletins, etc.) However, the ASC is not a complete or authoritative source for SEC rules and guidance Users of the ASC who work in the public company realm should continue to refer directly to the SEC body of literature to ensure accounting, classification and disclosures comply with SEC rules as well For example, SAB Topic 14 Share-Based Payment expresses the views of the staff regarding valuation of share-based payment arrangements for public companies

67 12 Referring Outside The ASC (Cont.) Industry practices Specific industries have specific practices that are generally accepted but not included in the ASC Depending on your industry, you may need to look outside the ASC for further guidance Oil and gas and real estate are examples of industries where nonauthoritative guidance might apply

68 13 The Bottom Line To summarize, the ASC: Simplified and streamlined the body of authoritative U.S. GAAP Changed the way users and preparers will research and cite accounting standards To effectively utilize the ASC: Subscribe to either the professional view of the FASB ASC Research System or a similar third-party tool, in order to access the enhanced research features Review your existing accounting policies now and determine where that literature resides in the ASC Begin experimenting now with the ASC

69 14 The Bottom Line (Cont.) The ASC should simplify the preparation of financial statements and research of accounting issues It should be viewed as a gift, but like an ipod, it takes getting used to However, once you know how to use the ASC, it s hard to understand what life was like before it came into existence

70 New FASB Accounting Standards Codification: Are You Ready? Webinar References To GAAP Under FASB ASC Michael Westervelt, LarsonAllen 1

71 Learning Objectives At the end of this session you will be: 1. Informed of the effective dates of the FASB Accounting Standards Codification 2. Made aware of presentation considerations for referencing standards in disclosures, footnotes, work papers, letters, etc. 3. Able to consider updating your deliverables to include more plain English wording rather than using specific reference to standards 2

72 FASB Accounting Standards Codification On July 1, 2009, the FASB Accounting Standards Codification became the single authoritative source of non-governmental U.S. GAAP (other than guidance issued by the SEC). After this date, any guidance not included in the Codification will be considered non-authoritative The Codification is effective for interim and annual periods ending after Sept. 15, 2009 The online Codification doesn t change GAAP, but it restructures the way it is organized. The goal is to make information easier to find, and in turn, make it easier to comply with the accounting standards. This change affects financial statement preparers, auditors, analysts and academics alike As of July 1, 2009, FASB will no longer issue statements, interpretations, staff positions or EITF abstracts. Irrespective of how they would have been issued under the prior structure, all changes to GAAP will be issued in the form of Codification updates. New standards will be organized under the same section headings as those used in the Codification 3

73 Goals Of The Codification Simplify user access to all authoritative U.S. GAAP Reduce the amount of time and effort required to solve an accounting research issue Mitigate the risk of non-compliance with standards through improved usability of the literature Provide accurate information with real-time updates as new standards are released 4

74 Codification - Structure And Reference The Codification is organized by topics, subtopics, sections and paragraphs. For example, SFAS 34, Capitalization of Interest, paragraph 9, addresses assets qualifying for interest capitalization. This information is included in the Codification and referenced as FASB ASC Topic 835 Interest Subtopic Capitalization of Interest Section Scope and Scope Exceptions Paragraph Assets for Which Interest Shall Be Capitalized 5

75 Referencing The Codification In Financials For periods ending after Sept. 15, 2009, you should no longer reference prior FASB statements, FINs, EITFs, etc. FASB encourages the use of plain English to describe references in the future 6

76 Referencing The Codification In Financials (Cont.) Audit, attest or compilation and review work papers associated with financial statements for a period ending after Sept. 15, 2009 would also reflect the Codification, since the underlying financial statements (the subjects of those engagements) reference the Codification If an entity continues to follow grandfathered guidance not included in the Codification, you would still reference those standards (and not FASB ASC). An explanation and a partial listing of grandfathered guidance is included in FASB Statement No

77 Referencing Accounting Standards Periods ending before Sept. 15, 2009 There is no requirement to make reference to specific accounting standards in financial statement disclosures, although it may be difficult to avoid references when disclosing the adoption of new standards. Entities may continue to make reference to pre-codification standards when referencing GAAP for periods ending prior to the effective date of the Codification Entities may choose to provide references to both prior GAAP and the Codification when preparing financial statements with a period-end before the effective date. Entities may want to avoid only referencing the Codification, because the basis for preparing these financial statements would be pre-codification GAAP 8

78 Referencing Accounting Standards (Cont.) Periods ending after Sept. 15, 2009 For periods ending after Sept. 15, 2009, references to pre-codification GAAP should be replaced with references to the Codification For comparative financial statements, entities may choose to provide references to both the Codification and pre-codification GAAP, because the basis of the prior-year financial statements was pre-codification GAAP. This presentation may make financial statements verbose, so consider referencing only the Codification 9

79 Disclosure Example Previously we used this: The Company has elected to defer application of FASB Interpretation No. 48, Accounting for Uncertainty of Income Taxes. The Company follows Statement of Financial Accounting Standards No. 5, Accounting for Contingencies, in evaluating uncertain tax positions. Potential change: The Company has elected to defer the provisions of uncertain tax positions as addressed in FASB ASC The Company follows FASB ASC , in evaluating uncertain tax positions. 10

80 Disclosure Example (Cont.) Now, in plain English: The Company has elected to defer guidance in the income tax standard regarding recognition and measurement of uncertain tax positions. The Company follows the accounting standard for contingencies, in evaluating uncertain tax positions. 11

81 Additional Consideration - Old Footnote Contingencies In accordance with SFAS No. 5, Accounting for Contingencies, the Company records accruals for such contingencies when it is probable that a liability will be incurred and the amount of loss can be reasonably estimated based on historical claim activity and loss development factors. There can be no assurance there will not be an increase in the scope of these matters or that any future or pending lawsuits, claims, proceedings, or investigations will not be material. Ultimately, settlement of such contingencies could be significantly different from the estimated amounts accrued at December 31,

82 New Footnote Contingencies The Company records accruals for contingencies when it is probable that a liability will be incurred and the amount of loss can be reasonably estimated based on historical claim activity and loss development factors. There can be no assurance there will not be an increase in the scope of these matters or that any future or pending lawsuits, claims, proceedings, or investigations will not be material. Ultimate settlement of such contingencies could be significantly different from the estimated amounts accrued at December 31,

83 Old Footnote Long-lived assets Under the provisions of SFAS No. 144, Accounting for the Impairment or Disposal of Long-Lived Assets, the Company evaluates its long-lived assets for impairment as events or changes in circumstances indicate that the carrying amount of such assets may not be fully recoverable. In such circumstances, the Company evaluates the recoverability of long-lived assets by measuring the carrying amount of the assets against the estimated undiscounted future cash flows associated with such assets. At the time such evaluations indicate the future undiscounted cash flows of certain long-lived assets are not sufficient to recover the carrying value of such assets, the assets are adjusted to their fair values. As of December 31, 2009 and 2008, management believes the carrying amounts of the remainder of long-lived assets have not been impaired under SFAS No

84 New Footnote Long-lived assets The Company evaluates its long-lived assets for impairment as events or changes in circumstances indicate that the carrying amount of such assets may not be fully recoverable. In such circumstances, the Company evaluates the recoverability of long-lived assets by measuring the carrying amount of the assets against the estimated undiscounted future cash flows associated with such assets. At the time such evaluations indicate the future undiscounted cash flows of certain long-lived assets are not sufficient to recover the carrying value of such assets, the assets are adjusted to their fair values. As of December 31, 2009 and 2008, management believes the carrying amounts of the remainder of long-lived assets have not been impaired. 15

85 Disclosure Summary Many more examples could be provided, but the main goal is to: Ensure the proper references are used depending on period of reporting. Before Sept. 15, 2009 After Sept. 15, 2009 When possible, use plain English to help the reader understand the financial statements 16

86 Representation Letters In the past, we preparers may have represented There are no: Violations or possible violations of laws or regulations whose effect should be considered for disclosure in the financial statements or as a basis for recording a loss contingency Unasserted claims or assessments that our lawyer has advised us are probable of assertion and must be disclosed in accordance with Statement of Financial Accounting Standards No. 5 Other liabilities or gain or loss contingencies that are required to be accrued or disclosed by Statement of Financial Accounting Standards No. 5 17

87 Representation Letters (Cont.) Going forward, we preparers should represent There are no: Violations or possible violations of laws or regulations whose effect should be considered for disclosure in the financial statements or as a basis for recording a loss contingency Unasserted claims or assessments that our lawyer has advised us are probable of assertion and must be disclosed in accordance with FASB ASC 450 (formerly Statement of Financial Accounting Standards No. 5) Other liabilities or gain or loss contingencies that are required to be accrued or disclosed by FASB ASC 450 (formerly Statement of Financial Accounting Standards No. 5 18

88 Representation Letters (Cont.) Why should we make reference to the previous standard as follows in certain circumstances? Unasserted claims or assessments that our lawyer has advised us are probable of assertion and must be disclosed in accordance with FASB ASC 450 (formerly Statement of Financial Accounting Standards No. 5) Until everyone is familiar with the new references, we want to ensure that there is no misunderstanding when making reference to a specific standard. So, in some cases, it may be prudent to refer to both old and new Possible plain English wording, but would suggest reference to standard Unasserted claims or assessments that our lawyer has advised us are probable of assertion and the amount of loss can be reasonably estimated based on historical claim activity and loss development factors, which must be disclosed 19

89 Legal Confirmations Remember, attorneys are familiar with Statement of Financial Accounting Standards No. 5 when considering unasserted claims or assessments and may not be familiar with reference to FASB ASC 450. So, consider the need to include dual reference when preparing legal confirmations This will Aid in ensuring proper understanding and response to legal confirmations 20

90 Work Paper Considerations Remember: The FASB Accounting Standards Codification TM is the single source of non-governmental authoritative U.S. GAAP for interim and annual periods ending after Sept. 15, At that same time, all previous level a-d U.S. GAAP standards issued by a standard setter are superseded Therefore, care should be given if reference is made to the precodification standards, as these standards may have been superseded When documenting research we should be using the Codification source material or source libraries, which are updated for changes in Codification standards timely Consider updating historical audit documentation carried forward from prior years, such as audit schedules and memos, to reflect FASB ASC 21

91 New FASB Accounting Standards Codification: Are You Ready? Webinar Oct. 14, 2009 Special Concerns For Attorneys; Codification s Impact Beyond Financial Statements Gordon S. Weber, Faegre & Benson LLP gweber@faegre.com

92 SEC Reports Historically Have Included References To Accounting Standards Annual reports on Form 10-K Quarterly reports on Form 10-Q Proxy statements Current reports on Form 8-K 2

93 Accounting Standards References In Reports On Form 10-K And Form 10-Q MD&A Recent accounting pronouncements MD&A Critical accounting policies and estimates MD&A Results of operations; liquidity and capital Resources Risk factors Quantitative and qualitative disclosures about market risk 3

94 Accounting Standards References In Other SEC Filings Proxy statements Compensation discussion and analysis Form 8-K; Item 2.03 Creation of a direct financial obligation or an obligation under an off-balance sheet arrangement of a registrant Form 8-K; Item 2.06 Material impairments Form 8-K; Item 4.02 Non-reliance on previously issued financial statements, a related audit report or completed interim review 4

95 General Approach To Revising Legacy GAAP References In SEC Filings Approach legacy GAAP references in SEC filings similar to legacy GAAP references in financial statement footnotes For footnotes, in its FASB Accounting Standards Codification Notice to Constituents (v 3.0), the FASB encourages the use of plain English to describe broad Topic references 5

96 Example Revisions To A Legacy GAAP Reference Before: Compensation expense included $X.X million non-cash stock-based compensation recognized in accordance with SFAS No. 123(R) After: Compensation expense included $X.X million non-cash stock-based compensation recognized in accordance with the Stock Compensation Topic of the FASB Accounting Standards Codification 6

97 Practical Considerations Some legacy standards may align with multiple Codification Topics (e.g., SFAS No. 109 Accounting for Income Taxes cross references to 12 different Codification Topics) Some legacy accounting standards have been grandfathered. Three other standards, which are not yet effective, are not currently incorporated into the Codification References to rules and interpretive releases of the SEC, such as staff accounting bulletins, remain valid 7

98 Technical Issue: Continuing Applicability Of SEC Rules SFAS No. 168 reiterates that, in addition to the Codification, rules and interpretive releases of the SEC under federal securities laws continue to be sources of authoritative GAAP for public reporting companies 8

99 Citations In SEC Rules To Legacy GAAP References Many SEC disclosure requirements cite specific legacy accounting standards For example, in describing the disclosure requirements for a table of contractual obligations, Item 303(a)(5) of Regulation S-K defines Long-Term Debt Obligation with a reference to SFAS No. 47 and defines Capital Lease Obligation with a reference to SFAS No. 13 9

100 Status Of Legacy Standards Cited In SEC Rules Issue: Does the citation to a legacy accounting standard in an SEC rule mean that the legacy standard remains GAAP for public reporting companies? Answer: No; on Aug. 18, 2009, the SEC issued Release No , which provides that references in the Commission s rules and staff guidance to specific standards under U.S. GAAP should be understood to mean the corresponding reference in the FASB Codification. 10

101 Legal Confirmations Standard forms of audit request letters and attorney responses include a reference to SFAS No. 5 Accounting for Contingencies The ABA Business Law Section, Audit Response Sub-Committee is evaluating the issue and will probably propose that the reference be revised to Codification Subtopic (Loss Contingencies) 11

102 The Codification And XBRL In XBRL, financial statement elements are tagged with a code based on an XBRL taxonomy SEC reporting companies with over $5 billion in market capitalization are required to file an XBRL exhibit to their financial statements for quarters ending after June 15,

103 The Codification And XBRL (Cont.) Issue: The official U.S. GAAP Taxonomy for 2009 issued by XBRL U.S. referred only to legacy accounting standards, not to the Codification Solution: XBRL U.S. issued a second, unofficial, U.S. GAAP taxonomy for 2009 that includes references to the Codification. More importantly, the GAAP citations are not part of XBRL tags. They are only a reference to assist in determining the proper XBRL tag 13