FASB Offers Guidance on Lease Concessions

A Guideline for COVID-19-Related Lease Modifications

On April 8, 2020, the staff of the Financial Accounting Standards Board ("FASB") responded to a question from constituents on whether the accounting for modifications in Accounting Standards Codification ("ASC") Topic 842 Leases or Topic 840 Leases applies to lease concessions (i.e., deferrals or forgiveness of lease payments) provided as a result of the effects of the COVID-19 pandemic. Subsequently, the FASB staff posted a Q&A document to the FASB web site that provides the following guidance:

...the FASB staff believes that it would be acceptable for entities to make an election to account for lease concessions related to the effects of the COVID-19 pandemic consistent with how those concessions would be accounted for under Topic 842 and Topic 840 as though enforceable rights and obligations for those concessions existed (regardless of whether those enforceable rights and obligations for the concessions explicitly exist in the contract).

The effect of the FASB staff guidance is that lessees and lessors will not be required to review their lease agreements to determine whether a concession granted by the lessor is consistent with the original terms of the lease agreement. Prior to the issuance of the FASB staff guidance, if a concession granted by a lessor was not required by the terms of the lease agreement, both the lessee and the lessor would need to account for the concession as a modification under either Topic 842 or Topic 840.