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Home > Library > Stable Times > Volume 5, Issue 2

The quarterly publication of the Stable Value Investment Association
Second Quarter 2001 • Volume 5 Issue 2
Update on Synthetic GICs
By Gina Mitchell, SVIA
As you may recall,
SVIA sent you a notice on May 8 indicating that the FASB Derivatives Implementation
Group had concluded that synthetic GICs are derivatives under SFAS 133
for issuers. This Group (referred to as DIG) described this conclusion
in a statement known as Issue A16. As noted in that May 8 communication,
there is disagreement on FASB's classification of synthetic GICs as a
derivative. Some points of disagreement are highlighted in the letter
PRIMCO Capital Management sent to FASB. PRIMCO's letter is posted on the
SVIA website.
In general, issuers did not react to Issue A-16's conclusions. Under Issue
A-16, issuers are required to report synthetics in corporate financial
statements. From an issuers' perspective, members reported this change
as having an immaterial impact on income statements.
The implementation of SFAS 133 has resulted in questions relating to the
appropriate accounting treatment for a defined contribution plan's investment
in a synthetic GIC. Even though Issue A-16 did not apply to the purchasers
of synthetic GICs, there has been some confusion with plan sponsors and
auditors as to whether to apply SFAS 133's fair value criteria or SOP
94-4's book value accounting for the synthetic GIC.
To date, four inquiries have been made to our stable manager members from
plan sponsors and their auditors for defined contribution plans with June
30, 2001 year ends. All of these inquiries have been resolved and book
value accounting was used for the plans' investment in the synthetic GIC.
In light of these questions, SVIA has established a Working Group to address
this issue. The list of SFAS 133 Working Group members is attached for
your information.
The Working Group is encouraging the AICPA to establish a Task Force to
provide guidance on the application of SFAS 133 to synthetics held by
defined contribution plans. The SVIA believes that synthetic GICS are
not derivatives and that SOP 94-4, which upheld book value treatment for
stable value funds, is appropriate for determining the reported value
of synthetic GICS for defined contribution plan financial statements and
plan participant statements. The Working Group has been successful in
making the AICPA aware of the importance of the stable value industry's
concerns on this issue.
A project proposal is being developed by the Chairman of the AICPA's Employee
Benefit Plans Expert Panel to study and formulate guidance on how SFAS
133 applies to synthetic GICs held by defined contribution plans. The
proposal must be considered and approved by the AICPA's Executive Committee,
known as AcSEC, to go forward. The AcSEC may consider the project proposal
in late July. Updates will be provided on the project proposal and the
work of SVIA's Working Group as progress is made. During this period,
book value accounting as set forth in SOP 94-4 is and continues to be
appropriate for reporting synthetic GICs in defined contribution pension
plan financial statements and participant communications.
Should you receive inquiries from your clients or auditors on synthetic
GICs held in defined contribution plans, SVIA is here to assist you. Please
call upon me at 202-261-6528.
View a list of the SVIA SFAS 133 group members.
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