Quarterly Accounting Roundup: Important developments with a special focus on non-gaap measures The Dbriefs Financial Reporting series Bob Uhl,

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Quarterly Accounting Roundup: Important developments with a special focus on non-gaap measures The Dbriefs Financial Reporting series Bob Uhl, Partner, Deloitte & Touche LLP

1 Quarterly Accounting Roundup: Important developments with a special focus on non-gaap measures The Dbriefs Financial Reporting series Bob Uhl, Partner, Deloitte & Touche LLP Christine Mazor, Partner, Deloitte & Touche LLP Joe DiLeo, Managing Director, Deloitte & Touche LLP Nick Tricarichi, Senior Manager, Deloitte & Touche LLP September 19, 2016

2 Agenda Non-GAAP measures Revenue recognition implementation efforts FASB standard setting SEC proposal on disclosures Question and answer Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 2

3 Keep in mind This webcast does not provide official Deloitte & Touche LLP interpretive accounting guidance. Check with a qualified advisor before taking any action. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 3

4 Learning objective To enhance participants understanding of important accounting issues and developments pertaining to recent actions of standard setters, regulators, and others. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 4

5 Polling question #1 Are you a financial statement preparer, user, auditor, or other interested party? Preparer User Auditor Other Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 5

7 Non-GAAP measures Background Non-GAAP comments have increased as a % of total SEC comments Call for registrants to self-correct Concerns about the increased use and prominence Dramatic increase in press coverage and increasing SEC focus Issuance of updated C&DIs Larger differences between such measures and amounts reported under GAAP Potential for such measures to be misleading Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 7

8 Non-GAAP measures The rules SEC Rule Regulation G Item 10(e) of Regulation S-K Overview of the requirements Non-GAAP financial measures must not be misleading. The most directly comparable GAAP measure must be presented. A quantitative reconciliation of the non-gaap financial measure to the most comparable GAAP measure must be presented for: a historical non-gaap measure and forward-looking information (to the extent available without unreasonable effort) Expands upon Reg. G requirements to also include: Present most directly comparable GAAP measure with greater or equal prominence of that of the non-gaap measure Disclosure indicating why the registrant believes that the non-gaap measure is useful to investors Disclosure of the additional purposes, if any, for which the registrant uses the non-gaap measure EBIT, EBITDA, adjusted EBITDA Adjusted EPS Common non- GAAP measures Adjusted net income Free cash flow Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 8

9 Polling question #2 Does your organization (or client or company you follow) report non-gaap measures? Yes No I am not sure Not applicable Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 9

10 Non-GAAP measures Updated compliance and disclosure interpretations More prominent presentation of non-gaap measures (C&DI ) Full non-gaap income statement Omitting comparable GAAP measures from press release headlines Bolder or larger font Non-GAAP measure that precedes a comparable GAAP measure Equally prominent description for a GAAP measure (e.g. record performance ) Disclosures related to forward looking non-gaap measures Same discussion and prominence for GAAP measures Tabular disclosure/reconciliation that starts with a non-gaap measure Non-GAAP measures are intended to supplement and not supplant the information in the financial statements. -Jim Schnurr, Chief Accountant, Office of the Chief Accountant Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 10

11 Non-GAAP measures Updated compliance and disclosure interpretations Misleading measures (C&DI ) Financial measures using individually tailored accounting principles (C&DI 100.4) Using a registrants' own set of accounting principles to determine a non-gaap measure Staff may not object to a measure that adjusts to reflect the adoption of the new revenue recognition accounting standard Prohibition on presenting liquidity measures on a per share basis (C&DI ) Designated performance measures that are really liquidity measures Non-GAAP tax expense (C&DI ) Tax adjustments commensurate with the non-gaap measure of profitability Clear explanation of how the adjustment was determined Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 11

12 Polling question #3 Has your organization (or client or company you follow) made changes to presentation and disclosure of non-gaap measures since the issuance of the updated C&DIs in May? Yes No I don t know Not applicable the organization does not present non-gaap Measures Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 12

13 Non-GAAP measures SEC comment letter trends Recent areas of focus Prominence: When a registrant presents its non-gaap financial measures more prominently than its GAAP measures (e.g., the registrant presents them before, or places greater emphasis on them than its GAAP measures, or presents a full non-gaap Income Statement) Sample comment: We note that in your executive summary you focus on key non-gaap financial measures and not GAAP financial measures which may be inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, 2016 (specifically Question ). We also note issues related to prominence within your earnings release.... Please review this guidance when preparing your next earnings release. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 13

14 Non-GAAP measures (cont.) SEC comment letter trends Recent areas of focus Purpose and use: Includes comments on whether the disclosures demonstrate the purpose of the measures (i.e., their usefulness to investors and how management uses them). Sample comment: Please revise to disclose the reasons why you believe your presentation of each of the non-gaap financial measures provides useful information to investors regarding your financial condition and results of operations. The justification for the use of the non- GAAP financial measure must be substantive. Merely indicating that you provide such non-gaap financial measures to give investors additional data to evaluate your operations is not sufficient support for disclosure of the non-gaap financial measures. Please also revise to expand your disclosure of the additional purposes for which management uses each of the non-gaap financial measures. Please refer to Item 10(e) of Regulation S-K. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 14

15 Non-GAAP measures (cont.) SEC comment letter trends Recent areas of focus Impact of income taxes: comments on the calculation of the tax impact of non-gaap adjustments and the related disclosures. Sample comment: Please expand your disclosures to explain how you calculated the tax effect for the adjustments to net (loss) income attributable to... and per diluted share in accordance with the guidance in Question of the Non-GAAP Financial Measures Compliance & Disclosure Interpretations. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 15

16 Non-GAAP measures (cont.) SEC comment letter trends Recent areas of focus Nature of adjustments: Comments on the nature of reconciling adjustments and the related disclosures. Sample comment: We note that your non-gaap measures exclude purchased intangible amortization, restructuring costs, asset impairments, acquisition-related costs, and income tax items and that you describe these items as infrequent or unusual although you have reported similar items for multiple fiscal years. Please note that Item 10(e)(1)(i)(A) of Regulation S-K prohibits you from adjusting a non-gaap performance measure to eliminate or smooth items identified as non-recurring, infrequent or unusual, when the nature of the charge or gain is such that it is reasonably likely to recur within two years or there was a similar charge or gain within the prior two years. In addition, your non-gaap measures appear to exclude certain normal, recurring, cash operating expenses which is inconsistent with the updated Compliance and Disclosure Interpretations issued on May 17, Please review this guidance when preparing your next earnings release. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 16

17 Non-GAAP measures What s next? Other areas of potential SEC comments More to come? Potential rulemaking Enforcement Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 17

18 Non-GAAP measures Disclosure controls and procedures Disclosure Controls and Procedures (DCPs) over non-gaap Design DCPS to ensure that procedures cover: Compliance NGM presented in compliance with rules, regulations and guidance Consistency Data quality Accuracy Transparent disclosure Review Monitoring Adjustments evaluated and presented in an appropriate and consistent manner each period Calculated based on reliable inputs Calculation is arithmetically accurate Descriptions of adjustments and required disclosures are clear and not confusing Reviewed by the appropriate levels of management Internal audit, disclosure committee or audit committee reviews the controls or is involved in the oversight Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 18

19 Non-GAAP measures Non-GAAP measures What to ask? 1. Is the measure misleading or prohibited? 2. Is the measure presented with the most directly comparable GAAP measure and with no greater prominence than the GAAP measure? 3. Is the measure appropriately defined and described, and clearly labeled as non- GAAP? 4. Does the reconciliation between the GAAP and non-gaap measure clearly label and describe the nature of each adjustment, and is each adjustment appropriate? 6. Is there transparent and company-specific disclosure of the reason(s) why the measure is useful for investors and the purpose for which management uses the measure? 7. Is the measure balanced (i.e., it adjusts not only for nonrecurring expenses but also for nonrecurring gains) and consistently prepared? 8. Does the measure appropriately focus on material adjustments and not include immaterial adjustments that would not seem to be a focus of management? 9. Do the disclosure controls and procedures address non-gaap measures? 10. Is the audit committee involved in the oversight of the preparation and use of non- GAAP measures? Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 19

20 Polling question #4 What is the most important reason for reporting non-gaap measures in earnings releases? To provide a more comprehensive picture of a company s finances To provide useful supplemental information to investors and shareholders Opportunity to define financial measures by industry to achieve some consistency among companies To provide insight into items that might be impacting comparability Don t know / Not applicable Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 20

22 Implementation efforts Key participants FASB & IASB boards Amend standard for clarifications and practical expedients SEC Staff announcements AICPA 16 Industry-specific working groups Audit & Accounting Guides PCAOB Auditors TRG Inform the boards of implementation issues Quarterly meetings Preparers Users ASU / IFRS 15 Issued May 2014 Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 22

23 Implementation efforts TRG Joint Revenue Transition Resource Group Jointly discussed about 40 topics in six meetings over approximately 18 months Led to standard-setting to further clarify ASC 606 Four final ASUs and one proposed ASU (regarding certain technical corrections) No longer joint (in January 2016, IASB announced it has completed its decision-making) Three FASB-only meetings scheduled in 2016 TRG met in April but did not meet in July Recent SEC staff comments expressing expectations of U.S. and foreign filers: SEC staff will consider TRG discussions and meeting minutes when assessing the appropriateness of a filer s revenue recognition accounting policies. Therefore, filers should monitor and consider such information (i.e., particularly when general agreement is reached). Strongly encourage filers to consult with the SEC staff if a filer anticipates selecting an accounting policy that is inconsistent with TRG discussions. Although IFRS constituents will no longer participate in TRG meetings, U.S. TRG participants are expected to discuss topics from a global perspective. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 23

24 Implementation efforts AICPA industry revenue task forces Number of issues that the task forces are addressing: No. of issues No. of issues Aerospace and defense 14 Hospitality 7 Airlines 20 Insurance 6 Asset management 10 Not-for-profit 5 Broker-dealers 9 Oil and gas 3 Construction contractors 11 Power and utility 10 Depository institutions 6 Software 13 Gaming 15 Telecommunications 12 Health care 10 Timeshare 12 Total Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 24

25 Implementation efforts Other considerations for SEC registrants SAB Topic 11.M (SAB 74) disclosures Important for investors timely education and engagement Disclosure of specific impact of new standard to the registrant expected to be more precise as effective date approaches Staff has cited how transparent disclosures regarding the adoption of other new standards prevented adverse market reactions Revised financial statements in registration statements Fourth year and impracticability Consultations and resources Office of the Chief Accountant (OCA) has conducted consultations and encourages registrants to consult with OCA Regarding complex, innovative transactions without clear guidance Topic 11 recently added to Division of Corporation Finance s Financial Reporting Manual Selected financial data, quarterly financial data, ratio of earnings to fixed charges Significance tests related to provision of other entities financial statements Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 25

26 Polling question #5 How far along is your company (or client) in its preparations to adopt the new revenue recognition guidance: In early stages of trying to understand the new requirements Assessing the appropriate accounting under the new guidance for the various types of contracts Completed assessment of what will change for the company and working to update internal control systems Don t know / Not applicable Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 26

28 Income taxes - Disclosure framework Overview of the proposed ASU The proposed ASU, which was issued in July 2016, (1) modifies or eliminates certain disclosure requirements and (2) establishes certain new disclosures under ASC 740 The proposed amendments would apply to all entities subject to income tax; however, certain amendments apply only to public business entities Transition and effective date The amendments in the proposed ASU would be applied on a prospective basis An effective date will be determined after consideration of all stakeholder feedback Next steps The proposed ASU has a comment period ending on September 30, 2016 Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 28

29 Income taxes - Disclosure framework Disclosure requirements - all entities Additions An explanation of any changes to an indefinite reinvestment assertion made during the year The aggregate amount of cash, cash equivalents, and marketable securities held by foreign subsidiaries Disaggregation between foreign and domestic (1) pre-tax income (loss) from continuing operations, (2) tax expense (benefit) from continuing operations, and (3) income taxes paid Income taxes paid must be further disaggregated by significant countries Enacted tax law change, if probable that change will affect entity in future period The gross (not tax-effected) amounts of federal, state, and foreign carryforwards Certain information regarding government assistance Subtractions Details of tax positions for which it is reasonably possible that the total amount of unrecognized tax benefits will significantly increase or decrease in the next 12 months. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 29

30 Income taxes - Disclosure framework Disclosure requirements public business entities only Additions In the tabular reconciliation of unrecognized tax benefits (UTBs), disaggregate settlements using existing tax assets separate from those that are settled in cash Breakdown (i.e., mapping) of amount of total UTBs shown in the tabular reconciliation by the respective balance sheet lines on which such UTBs are recorded Separate disclosure required for UTBs that are not presented in the balance sheet The gross and tax-effected amounts (before valuation allowance) of federal, state, and foreign carryforwards by period of expiration for the first 5 years after the reporting date and the total for any remaining years Disaggregation and separate presentation of components in the rate reconciliation that are greater than or equal to 5 percent of the tax at the statutory rate The amount and explanation of the valuation allowance recognized and/or released during the period Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 30

32 Hedging project Proposed ASU Project at a glance What hasn t changed Highly effective effectiveness threshold retained Benchmark interest rate concept for fair value hedges (hedges of fixed-rate financial instruments) Voluntary dedesignation of a hedging relationship Required timing for preparation of all hedge documentation except that relating to the initial quantitative prospective hedge effectiveness assessment What has changed? Presentation of periodic hedge ineffectiveness Recognition and presentation of changes in the fair value All changes in FV for highly effective hedges go to OCI (CF and net investment hedges) or P&L (FV hedges) Also recognize in current earnings amounts excluded from the hedge effectiveness assessment When recognized in P&L same line item as earnings effect of hedged item (except excluded amounts for NI hedges) Addition to benchmark interest rates Benchmark interest rate concept for hedging cash flows of variable-rate instruments eliminatedwill be able to designate the contractually-specified index rate as the hedged risk Ability to hedge contractually-specified components within the price of forecasted purchase/sale of nonfinancial assets Added new disclosure requirements and amended existing requirements Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 32

33 Hedging project Proposed ASU Project at a glance (cont.) Areas where relief has been proposed Need for subsequent quantitative effectiveness assessments Timing of initial prospective quantitative hedge effectiveness assessment Designation of fallback long haul method for shortcut method (if fail shortcut) Allow application of the shortcut method to partial term FV hedges of interest rate risk Certain fair value hedges of interest rate risk Option to use either the benchmark interest rate component of total contractual coupon cash flows or the total contractual coupon cash flows to calculate the change in the fair value of the hedged item attributable to changes in the BM rate Fair value hedges of prepayable instruments (i.e. callable debt) Ability to designate a portion of the term of a financial instrument as the hedged risk. Permit use of critical-terms-match method for cash flow hedge of groups of forecasted transactions Adoption and transition Modified retrospective Early adoption permitted at the beginning of any fiscal period before the effective date All amendments must be adopted at one date Effective date TBD Need to provide certain transition disclosures Certain transition provisions and one-time transition elections Comments due Nov. 22 nd (Nov. 4 th if participating in public roundtables) Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 33

34 Polling question #6 What impact do you believe the FASB s Disclosure Framework project will have on the effectiveness of disclosures? Improvement in disclosures Little or no improvement More unnecessary disclosures Loss of important disclosures Don t know / Not applicable Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 34

36 FASB invitation to comment Overview of the agenda consultation On August 4 th, the FASB issued an invitation to comment (ITC) to solicit feedback about potential financial accounting and reporting topics that it should add to its agenda. The ITC identifies financial reporting issues and possible solutions for the following topics: 1. Intangible assets (including research and development) 2. Pensions and other postretirement benefit plans 3. Distinguishing liabilities from equity 4. Reporting performance and cash flows (includes income statement, segment reporting, other comprehensive income, and statement of cash flows) The comment period ends on October 17 th Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 36

37 FASB invitation to comment Intangible assets Issue - lack of overarching recognition and measurement framework for internally developed intangible assets Potential improvements Alternative A - Recognize at cost or fair value internally generated intangible assets Alternative B - Recognize at cost or fair value research and/or development costs Alternative C - Disclose internally generated intangible items Alternative D - Adopt IAS 38 Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 37

38 FASB invitation to comment Pensions and other postretirement benefits Issue - Delayed recognition (smoothing) in earnings Potential improvements Alternative A - converge with IAS 19, Employee Benefits Alternative B - eliminate all smoothing and recognize measured changes immediately in the income statement The FASB is also considering whether a comprehensive change to pension and postretirement benefit plan accounting would be more effective Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 38

39 FASB invitation to comment Distinguishing liabilities from equity The issue - current GAAP is: 1. Difficult to navigate and 2. Internally inconsistent, conceptually flawed and rules-based (which can lead to financial structuring) Potential improvements Holistic approach to determine whether a present obligation to transfer shares of the entity meets the definition of a liability Alternative A Classify an instrument as a liability if there is a present obligation to transfer assets or shares of the entity Alternative B Classify an instrument as a liability only if there is a present obligation to transfer assets Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 39

40 FASB invitation to comment Reporting performance and cash flows Issues Income statement Other comprehensive income (OCI) Segment reporting Statement of cash flows Potential improvements 1. Categorize the income statement into operating and nonoperating activities 2. Combining or separating performance information and presenting discrete lines 1. Minimize the use of recycling 2. Remove the option for presenting comprehensive income over two statements 3. Emphasize other earnings-per-share measures 1. Reexamine disclosure requirements of ASC Reexamine aggregation criteria 3. View segment reporting from a governance perspective 1. Targeted improvement to provide further disaggregation of specific cash flows 2. Provide additional classification guidance for certain types of cash flows 3. Reconsider definitions of each classification category and the three-category structure Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 40

SEC Proposal to Eliminate Outdated and Duplicative Disclosures SEC Proposed Rule Release No. 33-10110 issued July 18, 2016.

42 SEC Proposal to Eliminate Outdated and Duplicative Disclosures SEC Proposed Rule Release No issued July 18, Would amend certain disclosure requirements that may be: Redundant, duplicative or outdated Overlap with other SEC, U.S. GAAP or IFRS disclosure requirements Proposal also seeks comments on certain SEC disclosure requirements that overlap with U.S. GAAP requirements (i.e., whether to refer such disclosures to the FASB for potential inclusion in U.S. GAAP). Would affect U.S. issuers, foreign private issuers, investment advisors, investment companies, broker dealers, and national recognized statistical rating organizations. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 42

43 Examples of proposed changes Refer to July 18, 2016 Heads Up for additional examples Category of proposed change Redundant or duplicative requirements Overlapping requirements* Outdated requirements Superseded requirements Goal of proposed change Eliminate requirements that result in substantially the same information under SEC rules, U.S. GAAP or IFRS Eliminate requirements that result in reasonably similar information or information that may no longer be useful to investors Amend requirements that are obsolete Amend requirements that are inconsistent with new requirements Example topic(s) affected (see proposal for specified changes) FX Consolidations debt obligations Consolidations Segments Market price disclosures Extraordinary items *Also seeks comment on whether to refer certain overlapping disclosures to the FASB for potential inclusion in U.S. GAAP. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 43

44 Polling question #7 From their Invitation to Comment, which financial accounting and reporting topic should the FASB add to its agenda: Intangible assets Pensions and other postretirement benefit plans Distinguishing liabilities from equity Reporting performance and cash flows Don t know / Not applicable Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 44

46 Join us October 17 at 2 p.m. ET as our Financial Reporting series presents: SEC hot topics: Year-end update Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 46

47 Eligible viewers may now download CPE certificates. Click the CPE icon in the dock at the bottom of your screen. CPE Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 47

48 Contact information Christine Mazor Partner Deloitte & Touche LLP Connect with me on LinkedIn Nick Tricarichi Senior Manager Deloitte & Touche LLP Connect with me on LinkedIn Bob Uhl Partner Deloitte & Touche LLP Connect with me on LinkedIn Joe DiLeo Managing Director Deloitte & Touche LLP Connect with me on LinkedIn Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 48

49 Acronyms used in presentation AFS Available for Sale AICPA American Institute of Certified Public Accountants ASC Accounting Standards Codification ASU Accounting Standards Update C&DI Compliance and Disclosure Interpretations EBIT Earnings Before Interest and Tax EBITDA Earnings Before Interest, Tax, Depreciation and Amortization EPS Earnings Per Share FASB Financial Accounting Standards Board FX Foreign Exchange GAAP Generally Accepted Accounting Principles IASB International Accounting Standards Board ICFR Internal Control over Financial Reporting IFRS International Financial Reporting Standards NGM Non-GAAP Measures SAB Staff Accounting Bulletins SEC Securities and Exchange Commission TRG - Transition Resource Group Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 49

50 This presentation contains general information only and Deloitte is not, by means of this presentation, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This presentation is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional advisor. Deloitte shall not be responsible for any loss sustained by any person who relies on this presentation. Copyright 2016 Deloitte Development LLC. All rights reserved. Quarterly Accounting Roundup: 50

About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ( DTTL ), its network of member firms, and their related entities.

51 About Deloitte Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee ( DTTL ), its network of member firms, and their related entities. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as Deloitte Global ) does not provide services to clients. Please see for a detailed description of DTTL and its member firms. Please see for a detailed description of the legal structure of Deloitte LLP and its subsidiaries. Certain services may not be available to attest clients under the rules and regulations of public accounting. Copyright 2016 Deloitte Development LLC. All rights reserved. 36 USC

FASB s targeted improvements to hedge accounting: Smoother sailing ahead? The Dbriefs Financial Reporting series

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