FASB Continues to Head in Right Direction on Multi-employer Plan Disclosure Standards

The Financial Accounting Standards Board (FASB or Board) at a June 29 meeting held further redeliberations of its proposal to update accounting standards related to disclosure of an employer’s participation in a multi-employer benefit plan.  The discussions are largely continuing in a direction favorable to AGC and to the Construction Industry FASB Coalition (CIFC), of which AGC is a member.  The original proposal – which was over broad and potentially very damaging to AGC members that contribute to multi-employer plans – has now been significantly pared back to a compromise that should achieve FASB's goal of greater transparency but without the severe consequences for construction firms. While one more meeting of deliberations is expected and changes could be introduced prior to a final decision, the Board on June 29 made the following tentative decisions regarding employers that contribute to multi-employer plans:

1.  An employer would be required to disclose:

a.  A description of the nature and effect of any changes affecting comparability from period to period for each period for which a statement of income is presented, including a business combination or a divestiture, the rate of employer contributions, and the number of employees subject to multi-employer pension plans; and b.  Information about plan assets and liabilities and total contributions to the multi-employer plan from all employers in circumstances in which the information is not available in the public domain.

2.  An employer would not be required to disclose any of the following:

a. Known trends in future contributions; b. Estimated amounts of future contributions; or c. The percentage of its employees covered by multi-employer plans.

3.   A subsidiary that participates in its parent entity’s single-employer defined benefit pension plan would be required to disclose the name of the parent plan and the amount of contributions made in each period for which an income statement is presented.

4.   The required disclosures would only apply to pension plans. For multi-employer health and welfare plans, certain aspects of the existing disclosure requirements will be clarified.  In addition, the Board may address other aspects of the disclosure requirements related to multi-employer health and welfare plans as part of a future project.

The Board also directed its staff to conduct outreach efforts with respect to the auditability of the following:

1.   The percentage of the employer’s total contributions to a multi-employer plan; and

2.   The disclosure of information about plan assets and liabilities and total contributions to a multi-employer plan in circumstances in which the information is not available outside of the financial statements.

The results of that outreach will be discussed at a future meeting. FASB, at a May 31 meeting, had already tentatively adopted the bulk of a CIFC-proposed compromise disclosure standard. Most notably, based on guidance provided by CIFC, FASB removed a requirement in its original proposal for the routine disclosure of estimated withdrawal liability.  The requirement appears to remain removed from consideration after the June 29 meeting. AGC and CIFC will continue to monitor developments and to work with FASB to help achieve an acceptable outcome. Click here to access a video archive of the June 29 FASB meeting.  Click here to access a copy of the meeting handout.