FAS 133 Derivatives Implementation
Statement 133 Implementation Issues provide guidance on questions that companies may face when implementing Statement 133. Implementation issues are authored by the FASB staff and represent the staff's views, although the Board has discussed the issues at a public meeting and chosen not to object to dissemination of that response. Official positions of the FASB are determined only after extensive due process and deliberation. Prior to April 2001 these issues were prepared with the assistance of the Derivatives Implementation Group, as described below.
When considering future Statement 133 Implementation Issues the FASB staff expects to follow procedures consistent with the issuance of FASB Staff Positions.
Implementation issues finalized before March 2004 are incorporated in the updated edition of Accounting for Derivative Instruments and Hedging Activities. Issues finalized subsequent to this date are available on this website (Guidance on Statement 133 Implementation Issues).
The Derivatives Implementation Group was a task force created in 1998 concurrent with the issuance of FASB Statement No. 133, Accounting for Derivative Instruments and Hedging Activities, to assist the FASB in providing guidance on questions that companies would face when they began implementing Statement 133. The FASB's objective in forming the group was to establish a mechanism to identify and resolve significant implementation questions in advance of the implementation of Statement 133 by many companies.
The role of the Derivatives Implementation Group was different from that of other task forces previously assembled by the FASB because it was established to address issues related to a new Statement that had not yet been implemented by most companies. The responsibilities of the Derivatives Implementation Group were to identify practice issues that arose from applying the requirements of Statement 133 and to advise the FASB on how to resolve those issues. In addition to members of the implementation group, any constituent or organization could have submitted questions to be debated by the group by sending a detailed letter to the group chairman, which has been either the FASB Vice Chairman or the Director of Research and Technical Activities. The FASB staff also sought input from the implementation group on selected technical inquiries that it resolved.
The model for the Derivatives Implementation Group was the Emerging Issues Task Force (EITF) with the key difference being that the Derivatives Implementation Group did not formally vote on issues to reach a consensus. Instead, the Chairman had the responsibility to identify an agreed-upon resolution that emerged based upon the group's debate. Implementation group members were free to submit written objections to any issue where the group had reached an agreed-upon resolution. In instances where no clear resolution of an issue had emerged, the issue would be discussed further at a future meeting or handled by the FASB staff.
After each meeting of the Derivatives Implementation Group, the FASB staff had the responsibility of documenting tentative conclusions for each issue. Those tentative conclusions were publicly available on the FASB web site typically several weeks after a meeting of the Derivatives Implementation Group. Those conclusions remained tentative until they were formally cleared by the FASB and became part of an FASB staff implementation guide (Q&A). The Board was typically not asked to formally clear the staff's tentative conclusions at a public Board meeting until those conclusions had been publicly available on the website for a 35-day period. That delay provided constituents the opportunity to study those conclusions and submit any comments before the Board considered formal clearance. The cleared Implementation Issues as well as any tentative conclusions are available for reference on this FASB website.
Meetings of the Derivatives Implementation Group were held at the FASB offices in Norwalk, CT and were open to public observation. The group met bimonthly from Mid-1998 through March 2001 when companies were planning for transition to the new accounting requirements. (Statement 133 was effective for all fiscal quarters of fiscal years beginning after June 15, 2000.) The Derivatives Implementation Group no longer meets.