Reporting Entity Purpose

To provide the Federal Accounting Standards Advisory Board’s (FASAB) Statements of Federal Financial Accounting Standards (SFFAS) No. 47, Reporting Entity determinations received by the federal entities, reviewed by the Working Group, and approved by the SFFAS No. 47 Steering Committee. The determinations are listed in Appendix 1b (Consolidation Entities, Disclosure Entities, and Related Parties).

Reporting Entity Background

A questionnaire was designed for implementation by compiling the key deciding factors throughout FASAB Standard No. 47 with the corresponding paragraphs in SFFAS No. 47 with each question. The questionnaire asked for the component reporting entity to be identified. Upon completion of the survey, the entity was led to a reporting determination of consolidation entity, disclosure entity, related party, or not required to report. Consistent with Appendices B & C of SFFAS No. 47, the survey requires component entities to document the rationale for their determinations as to other entities for each entity considered. It also requires entities to specify whether any other entities are component thereof (i.e., consolidation or disclosure), a related party or do not meet the criteria of SFFAS No. 47. Federal entities are required to confirm Reporting Entity determinations in Appendix 1b via an annual data call response. Entities should notify Fiscal Service if a survey is needed to document changes in rationale or for a new Reporting Entity determination.

The survey supported the following determinations*:

*See SFFAS No. 47, Reporting Entity for more detail.

The top-down approach was used to identify potential entities that meet the criteria of SFFAS No. 47 from a government-wide perspective. To ensure completeness, the component should perform a bottom-up assessment to identify entities that may not have been identified through the top-down approach. Each component entity should perform an entity review annually to validate proper reporting at the entity level. For assistance in an entity level review, please contact Fiscal Service at GTAS.Team@fiscal.treasury.gov to receive the SFFAS No. 47 Entity Analysis Excel workbook. Entities should notify Fiscal Service immediately if an entity analysis results in a determination(s) that differs from those outlined in Appendix 1b and include the basis for determination.

Component entities must notify Fiscal Service of any discrepancies between the auditor and the component entity as to the component entity’s reporting entity status determination. In addition, questions concerning which component entity a federal entity needs to be consolidated into must be discussed with Fiscal Service. Final reporting entity determinations must be agreed upon by the Department of the Treasury and OMB.

Reporting Entity Procedure/Requirements

Federal entities must report information based on the SFFAS No. 47 determination. The determinations are available in Appendix 1b and will be used to report Appendix A: Reporting Entity of the Financial Report of the United States Government.

An entity with the determination of consolidation will submit an ATB in GTAS. This data will flow to the face of the government-wide statements presented in the Financial Report.

SFFAS No. 34 recognizes that some federal reporting entities prepare and publish financial reports pursuant to the accounting and reporting standards issued by the Financial Accounting Standards Board (FASB). SFFAS No. 34 provides that certain entities' financial statements prepared in conformity with accounting standards issued by the FASB may be regarded as in conformity with U.S. Generally Accepted Accounting Principles (GAAP). Consolidation entities (that is, the consolidated government-wide reporting entity or a consolidated component reporting entity) may consolidate component or sub-component reporting entity financial statements prepared in accordance with SFFAS No. 34 without conversion for any differences in accounting policies among the organizations.

While reporting entities that prepare and publish financial reports pursuant to FASB standards are not required to convert reported amounts to account for any differences in accounting policies between FASB and FASAB, additional data/information may still be required to be reported to supplement government-wide disclosure and other reporting requirements. SFFAS No. 47, Footnote 27 allows that the Department of the Treasury and OMB will determine if there is a need for coordinated guidance to ensure government-wide consistency.

FASAB explains in the SFFAS No. 47 the basis for its conclusions that certain requirements for information (such as intra-governmental balances to facilitate eliminations at the government-wide level) are not required through accounting standards, but instead could be required by guidance from OMB and/or the Department of the Treasury (SFFAS No. 47, Par. A84).

Entities with a determination of disclosure or related party (see Appendix 1b) will continue to report TAS, if applicable, but when utilizing the disclosure or related party, TAS transactions must be processed as non-federal (N). This information is reported by the consolidation entities and not a direct report by the disclosure or related party. Therefore, if the entity has a relationship with a disclosure entity included in the government-wide financial statements or related party, make sure to report the federal or non-federal designation as non-federal.

Note: Several entities have expressed an interest in preparing subcomponent financial statements. These entities may be found in Appendix 1c. For complete details of SFFAS No. 47, please see: https://files.fasab.gov/pdffiles/handbook_sffas_47.pdf.

See the FY 2025 TFM Year-end Closing Bulletin for all the Financial Report reporting and submission dates regarding, but not limited to, GTAS, intra-governmental transactions/balances, legal counsel responses, Management Representation Letters (MRLs), and subsequent events.

Federal entity participation in the third quarter and/or year-end Financial Report reporting submission and collaboration initiatives will be measured on the entity’s year-end Financial Report and IGT Scorecards for the current FY. Entity performance measures include 1) timeliness; 2) timely/complete; 3) reconciliation of differences; 4) consistency and integrity; and 5) significant disclosures on key focus areas.

Federal entities should submit to Fiscal Service their POC information for internal representatives who are considered technical experts for financial reporting, restatements, legal counsel responses, MRL, Summary of Uncorrected Misstatements (SUM), and significant disclosures for key focus areas (key focus areas are listed in the FY 2025 TFM Year-end Closing Bulletin). These individuals will be the POC for close collaboration throughout interim analysis and year-end preparation of the Financial Report according to section 4710 above. Contact information must include name, phone number, email address, and area(s) of expertise and be submitted to Fiscal Service at financial.reports@fiscal.treasury.gov.

4730.10—Third Quarter Reporting (Unaudited Financial Statements and Notes)

The purpose of these submissions is to enable Fiscal Service to conduct preliminary analysis on federal entity data to facilitate preparation of the Financial Report.

4730.10a-Interim Financial Statements and Notes

Significant entities must submit unaudited interim financial statements and notes, as of June 30, in accordance with OMB Circular No. A-136 to notify Treasury of new disclosures or significant changes that have been made to their programs. Comparative interim financial statements are limited to the Balance Sheet, SNC, and SCNP. Please reference the FY 2025 TFM Year-end Closing Bulletin for guidance on transmission of applicable documents.

4730.10b-Significant Disclosures of Key Focus Areas

Fiscal Service will also require significant entities’ assistance with completing the analysis of ‘key” focus areas that present a greater risk of failing to meet the prescribed disclosure requirements and that are relatively new to the Financial Report. “Key focus areas” are notes, Required Supplementary Information (RSI), or Other Information (OI) identified as being affected by new or updated FASAB/FASB standards and notes, RSI, and OI that include topics that are prevalent in the current socioeconomic climate.

For “key” focus areas, Fiscal Service will provide the Significant Disclosures questionnaire on the GTAS website (Resources section). Federal entity technical experts are required to provide feedback on the Significant Disclosures questionnaire on items of significance that occurred during the FY that should be considered by Fiscal Service for disclosure in the Financial Report during its analysis and compilation process. Questions are to be submitted to Fiscal Service. Fiscal Service will also include a link to the prior year published Financial Report and any applicable auditor comments with the questionnaire. Please reference the FY 2025 TFM Year-end Closing Bulletin for guidance on transmission of applicable documents.

See the FY 2025 TFM Year-end Closing Bulletin for the dates the questionnaire will be available on the GTAS website and dates the completed questionnaires are to be returned to Fiscal Service. Federal entity participation in the third quarter collaboration initiative will be measured on the entity’s year-end Financial Report and IGT Scorecards for the current FY.

Key Focus Areas for FY 2025:

4730.20—Year-End Reporting (Audited Financial Statements and Notes)

4730.20a-Year-End Financial Statements, Notes, and Variance Analysis

All federal entities (significant and other) must submit audited financial statements and notes in accordance with OMB Circular No. A-136. Significant entities must submit a variance analysis in accordance with OMB Circular No. A-136, Section III.2, Please reference Section 4735 for additional financial reporting requirements. Please reference the FY 2025 TFM Year-end Closing Bulletin for guidance on the transmission of applicable documents and all the due dates.

4730.20b-Significant Disclosures of Key Focus Areas

Significant entities should be aware the significant disclosure Key focus areas process is also a requirement at year-end. Fiscal Service will provide the year-end Significant Disclosures questionnaire on the GTAS website. Federal entity technical experts must provide feedback on the Significant Disclosures questionnaire for items of significance that should be considered by Fiscal Service for disclosure in the Financial Report during the analysis and compilation process, along with the location of the disclosure in the entities’ financial statements. Responses are also required for the Immaterial Correction of Errors. See the FY 2025 TFM Year-end Closing Bulletin for the dates the questionnaire will be available on the GTAS website as well as the dates the completed questionnaires are to be returned to Fiscal Service. Participation in this collaboration process will also be measured on federal entities’ year-end Financial Report and IGT Scorecards.

Significant entities must:

Contact Fiscal Service to determine the reporting procedures for any adjustments to the GTAS data and AFR/PAR after their publication, which is normally November 15. For contact information, see the GTAS Contacts page.

4735.10—Federal Trading Partner Notes

Federal trading partners and amounts for each federal line item reported based on the reclassified financial statements will be derived from GTAS ATB data. Amounts identified as federal should be net of intra-departmental eliminations with the following exceptions:

Identifying the trading partner enables analysis and elimination of federal activity/balances based on reciprocal categories at the government-wide level. See Appendices 1a and 1b for a complete list of Agency Identifiers (AIDs) and financial reporting entities.

All General Fund of the U.S. Government (General Fund) activity will be reported to the appropriate reclassified financial statement line within RC 30–RC 48 activities. The General Fund activity based on the USSGL and federal/non-federal attributes will be reported to the appropriate reclassified financial statement line within RC 30–RC 48 (see Appendices 2 and 3 for the appropriate reclassification of reclassified financial statement lines) using a federal/non-federal attribute domain value of “G.” See Appendix 11 for more details on transactions with the General Fund.

4735.20—Reclassification of Significant Entities’ Financial Statements

Significant entities must submit GTAS ATB data. GTAS will then populate three reclassified financial statements based on the USSGL crosswalks. The USSGL crosswalks for the Standardized Balance Sheet can be found in USSGL guidance (current FY-Section V- USSGL Crosswalks to Standard External Reports) and the USSGL crosswalks for the Reclassified SNC, and the Reclassified SOCNP can be found in USSGL guidance (current FY–Section VI-Crosswalks to Reclassified Statements). Entities can access the entity GTAS reports titled “Balance Sheet, Reclassified SNC, and Reclassified SOCNP” which significant entities must use to complete Note 36: Reclassification of Financial Statement Line Items for Financial Report Compilation Process - Significant Entities Only per OMB Circular No. A-136. For Note 36 requirements, please refer to the OMB Circular No. A-136, Section IV.2.1–Significant Reporting Entities.

Note: If you are a significant entity and a FASB reporter, please refer to Section 4735.30 for additional information related to the Note 36 requirements.

Significant entities report the line items on their financial statements based on what is most material and useful to them. These line items may not match line items in the reclassified financial statements for several reasons. For example, the reclassified financial statement line items may not apply to the federal entity, the amounts could be immaterial at the entity level, or the entity may find it useful to include more detail than the reclassified financial statement lines. Federal entities must submit ATB data to GTAS for the reclassified financial statement lines, regardless of materiality.

4735.20a—Custodial Activity

Significant entities that report a Statement or Note on Custodial Activity in their comparative, audited consolidated, financial statements should show an adjustment of the exchange revenue without associated costs and non-exchange revenue from the Statement or Note on the Custodial Activity to the SOCNP on Note 36: Reclassification of Financial Statement Line Items in OMB Circular No. A-136. From the Sources of Collections section of the Custodial Statement or Note (with the exception of customs duties, excise taxes, and taxes collected by the Department of the Treasury, the Department of Labor (DOL), and the Department of Homeland Security (DHS)), reclassify all non-exchange revenue lines to “Other taxes and receipts” and exchange lines to “Miscellaneous earned revenue.” From the Disposition of Collections section, reclassify all federal lines to “Other Budgetary Financing Sources” and non-federal lines to “Other taxes and receipts.”

Federal entities must report the custodial revenue as non-federal “N” at the time of collection from the public (that is, the Sources of Collection section). The disposition of the custodial revenue to other federal entities must be reported as federal “F” in the Reclassified SNC or SOCNP when reporting in GTAS. Any federal entity receiving custodial revenue from the collecting entity must report this revenue as federal “F” in its Reclassified SNC or SOCNP when reporting in GTAS. If the collecting entity retains a portion of the custodial revenue, the entity must report this revenue as non-federal, “N” at the time of collection from the public. If the revenue is transferred between intra-departmental funds, those transactions should be reported as federal “F” in its Reclassified SNC or SOCNP when reporting in GTAS and must use its own trading partner AID. The federal entity must ensure the amounts reported with its own trading partner AID eliminate appropriately.

There may be situations in which custodial revenue collected in a TAS of one federal entity and, subsequently, transferred to another TAS (other than General Fund), is identified as inappropriate by the Department of the Treasury and OMB. Additionally, there may be situations in which there is not currently a TAS for the federal custodial entity to record the custodial collection and subsequent distribution. For both situations, Fiscal Service has worked with OMB to assign a series (F3600-F3699) of clearing accounts to coordinate the reporting of custodial activity between the two federal entities (neither of which are the General Fund). For additional information on the requirements for establishing one of these accounts, please email GovernmentwideIGT@fiscal.treasury.gov. Please see TFM Volume I, Part 2, Chapter 1500 for additional details on establishing new custodial clearing accounts.

If federal entities have collections that do not meet Statement or Note on Custodial Activity reporting requirements, they should refer to the General Fund Receipt Account Guide.

Please see Appendix 10 of this chapter, Custodial and Non-entity Transactions, for the intra-governmental custodial activity guidance.

For additional guidance on custodial activity, as well as how to classify certain related transactions, see SFFAS No. 7.

4735.20b—Funds From Dedicated Collections

Funds from dedicated collections are financed by specifically identified revenues, often supplemented by other financing sources, which remain available over time. These specifically identified revenues and other financing sources are required by statute to be used for designated activities, benefits, or purposes and must be accounted for separately from the government’s general revenues in accordance with SFFAS No. 27 as amended by SFFAS No. 43. SFFAS No. 43 modified the definition of these funds by clarifying that at least one source of fund, external to the federal government, must exist for a fund to qualify as a fund from dedicated collections. SFFAS No. 43 also added an explicit exclusion for any fund established to account for pensions, other retirement benefits, other post-employment, or other benefits provided for federal employees (civilian and military).

Entities with material amounts of funds from dedicated collections must use the templates outlined in OMB Circular No. A-136, which show funds from dedicated collections reported on the SOCNP on the consolidated basis and the note disclosure for funds from dedicated collection on both a combined and consolidated basis. Eliminations reflect intra-entity balances and transactions between the entity’s dedicated collections funds. Significant entities required to prepare financial statements in accordance with accounting standards other than those promulgated by FASAB will be contacted by Fiscal Service for dedicated collections information necessary for government-wide statements.

At the government-wide level, the U.S. government’s Balance Sheet shows separately the portion of the net position attributable to funds from dedicated collections and labels those lines accordingly. The SOCNP shows funds from dedicated collections as consolidated and labels the lines accordingly, while the note disclosure for funds from dedicated collections discloses combined totals, intra-governmental eliminations within funds from dedicated collections, and consolidated totals. Please refer to OMB Circular No. A-136 for more details.

In addition, the reclassification crosswalk will be needed to identify the difference of revenue presented on an entity’s SCNP to the government-wide SOCNP. Please refer to the Reclassification of Financial Statement Line Items for Financial Report Compilation Process area of the OMB Circular No. A-136 for more details.

Significant entities must ensure that funds from dedicated collections are denoted on the Super Master Account File (SMAF) in GTAS as an “E” for the Reporting Type Code. To request an “E” Reporting Type Code for a specific TAS, send an email to GTAS.team@fiscal.treasury.gov. This TAS designation will crosswalk the funds from dedicated collections amounts and activity to the applicable reclassified financial statement line items. For additional guidance, see OMB Circular No. A-136.

4735.20c—Criminal Debt

Criminal debt primarily consists of fines and restitution that result from a wide range of criminal activities, including domestic and international terrorism, drug trafficking, firearms activities, and white-collar fraud. When an individual is sentenced in a federal criminal case, the judge may order the defendant to pay certain financial obligations, which may include a case assessment, fine, restitution, penalty, bail bond forfeiture, or interest. The Department of Justice’s (DOJ) Executive Office for U.S. Attorneys is responsible for establishing policies and procedures for the collection of criminal monetary penalties. The U.S. Attorneys are responsible for the enforcement of judgments, fines, penalties, and forfeitures imposed in their respective districts. There are 93 U.S. Attorneys stationed throughout the 50 states, Puerto Rico, the Virgin Islands, Guam, and the Northern Mariana Islands. The U.S. Attorneys publish the Annual Statistical Report that contains statistical tables displaying both national and district caseload data, covering the many priorities of the U.S. Attorneys in both criminal prosecution and civil litigation. The data supporting the Annual Statistical Report is obtained from the DOJ Consolidated Debt Collection System (CDCS). The CDCS is the system of record for debts being collected by DOJ on behalf of others, including federal entities. The system is used by the U.S. Attorneys' Offices, DOJ’s other litigating divisions, and contracted Private Counsel Offices to monitor and track delinquent civil and criminal debts owed to the federal government. The funds collected in federal restitution are disbursed back to the appropriate federal entities, while funds collected in bond forfeitures, fines and assessments are deposited into the Crime Victims Fund. Funds collected from penalties and certain costs are deposited in the General Fund. The U.S. Courts assist DOJ with the receipt and distribution of financial obligations ordered in a criminal judgment and serve as a conduit between the defendant and DOJ. The majority of payments made to satisfy criminal restitution are received at the Clerk of Court offices. The Clerk of Court offices have the payee details from the criminal judgment to ensure proper disbursement of payments.

Non-exchange revenues include income taxes, excise taxes, employment taxes, duties, fines, penalties, and other inflows of resources arising from the government’s power to demand payments from the public. Non-exchange revenue should be recognized when a specifically identifiable, legally enforceable claim to resources arises, to the extent that collection is probable (more likely than not) and the amount is reasonably estimable (SFFAS No. 7, par. 48). For accounts receivable resulting from non-exchange transactions, recognition is based on the completion of the assessment process that establishes an identifiable, legally enforceable claim to cash or other assets (SFFAS No. 7, par. 53). Assessments recognized as accounts receivable include court actions determining an assessment (SFFAS No. 7, par. 54). Federal accounting standards require that an allowance for uncollectible amounts be established to reduce the gross amount of receivables to its net realizable value (SFFAS No. 1, par. 45).

Public Access to Court Electronic Records (PACER) is an electronic public access service that allows registered users to obtain case and docket information online from federal appellate, district, and bankruptcy courts. The Judgment in a Criminal Case form issued by a court is a public record filed with the Clerk of Courts. The criminal judgment form and related case documents can be obtained via PACER. The Judgment in a Criminal Case form includes a schedule for Criminal Monetary Penalties, which details if any assessments, fines, or restitution have been established in the final judgment in a criminal case and lists the payees and amount of restitution ordered for each payee. This schedule also indicates if the fine or restitution are subject to interest. The Judgment in a Criminal Case form also includes the Schedule of Payments, which lists the specific details as to when payments are to commence and the frequency of when payments are due. When a federal entity is listed as a payee in the Judgment in a Criminal Case form, the legally enforceable claim to cash or other assets is established.

Significant entities and other entities that are owed restitution as the result of a judgment in a criminal case are required, if material, to report in Note 6: Accounts Receivable, Net in OMB Circular No. A-136.

4735.20d—Social Insurance

The Statements of Social Insurance and the Statement of Changes in Social Insurance Amounts (SCSIA) are required by SFFAS Nos. 17, 25, 26, and 37 to be presented as basic financial statements. The Social Insurance reporting entities are the Social Security Administration (SSA), the Department of Health and Human Services (HHS), the Railroad Retirement Board (RRB), and DOL.

Most of the social insurance information pertaining to Social Security and Medicare can be obtained from SSA (the current year signed Annual Report of the Board of Trustees of the Federal Old-Age and Survivors Insurance and Federal Disability Insurance Trust Funds) and from HHS (the 2023 Annual Report of the Boards of the Trustees of the Federal Hospital Insurance and the Federal Supplementary Medical Insurance Trust Funds, and the Centers for Medicare and Medicaid Services' (CMS) Workbook). HHS will provide Fiscal Service the CMS Workbook for data entry purposes. The remaining data for social insurance from SSA and HHS will come from their AFR/PAR. It is noted that the social insurance information from RRB and DOL will come directly from their AFR/PAR. RRB, however, will provide to Fiscal Service a spreadsheet with the amounts of its current year SCSIA for data entry purposes. For additional guidance, see OMB Circular No. A-136.

4735.20e—Fiduciary Activities

In a fiduciary activity, the government collects or receives and subsequently manages, protects, accounts for, invests, and disposes of cash or other assets in which non-federal individuals or federal entities have an ownership interest that the government must uphold. Non-federal individuals and federal entities must have an ownership interest in the cash or other assets held by the government under provision of loan, regulation, or other fiduciary arrangement. The ownership interest must be enforceable against the government, and judicial remedies must be available for the breach of the government’s fiduciary obligation. Federal entities should account for this fiduciary activity, which includes the collection of cash or other assets and their distribution to the non-federal owners or their beneficiaries, in accordance with SFFAS No. 31. In accordance with the standard, there is relatively similar government activity that is specifically excluded from the SFFAS No. 31 reporting requirements, such as payroll withholdings and garnishments; unearned revenue; and seized property.

The standard requires that the government’s fiduciary activities and a description thereof be included as a note disclosure. In addition, the government must disclose that the fiduciary assets are not assets of the government and are, therefore, not recognized on the U.S. Government Balance Sheet. However, at the government-wide level, the U.S. Government Balance Sheet recognizes a liability for fiduciary Fund Balance with Treasury and a liability for fiduciary investments in U.S. Treasury securities that are included in the federal entities’ fiduciary assets. Federal entities must ensure proper TAS designation of their fiduciary TASs each fiscal year. This, in turn, ensures the fiduciary data crosswalks properly to the AFRs/PARs.

However, both significant entities and other entities with fiduciary activity must enter the federal entity fiduciary activity note disclosure information in Fiduciary Activities Note in the OMB Circular No. A-136.

Significant entities must ensure that fiduciary activities are denoted on the SMAF in GTAS as a “F” for Reporting Type Code. To request a “F” Reporting Type Code for a specific TAS, send an email to GTAS.Team@fiscal.treasury.gov and a description of how the TAS will be used.

4735.20f—Reporting of Government Account Series (GAS) Investments with Fiscal Service Purchased by Federal Entities Using Fiduciary or Non-fiduciary Funds

The Department of the Treasury GAS securities purchased using a non-fiduciary fund are normally classified as intra-governmental. The investments in GAS securities by non-fiduciary funds and the associated USSGL accounts should be reported with a federal/non-federal attribute domain value of “F” with a corresponding federal trading partner of 020 for the Department of the Treasury.

The purchase of the Department of the Treasury GAS securities using a fiduciary fund is not classified as intra-governmental. The investments in GAS securities by a fiduciary fund and the associated USSGL accounts should be reported with a federal/non-federal attribute domain value of "F” with a corresponding federal trading partner of 020 for the Department of the Treasury for budgetary reporting only. The balance will be excluded from the Balance Sheet when consolidating the Financial Report when reported by an account with Reporting Type Code attribute domain value “F” (fiduciary).

Note: The Department of the Treasury will still report the liability as federal debt and interest payable with federal/non-federal attribute domain value “N” to allow for appropriate Balance Sheet presentation on the Financial Report.

4735.20g—Department Code Reporting for General Fund Activities

Federal entities that record activities with the General Fund must properly record the activity at the government-wide level to assist with the preparation of the Financial Report. Refer to USSGL guidance (Section VI-Crosswalks to Reclassified Statements) for a description of each reclassified Financial Report line, and Appendices 2 and 3 for a listing of reclassified Financial Report line Reciprocal Category (RC) designations and the financial statement to which they relate. Please refer to Appendix 11 for full General Fund reporting guidance.

Federal entities should contact Fiscal Service, via email at GovernmentwideIGT@fiscal.treasury.gov, if they are unsure about what the correct trading partner assignment is for a particular transaction.

4735.20h—Non-reciprocating Activities

Z (intra-governmental)—This is an attribute domain value of a USSGL account balance that results from transactions that are intra-governmental in nature, but no reciprocal balances will be reported by any other federal entity. The attribute is limited to RC 29.

An example of a non-reciprocating activity is as follows:

4735.20i — Federal Lease Accounting

Statements of Federal Financial Accounting Standards

SFFAS No. 54, Leases, as amended by SFFAS No. 58, No. 60, No. 61. and No. 62, replaces proprietary lease accounting and disclosure standards for general purpose federal financial reports. Federal reporting entities should review SFFAS No. 54, as amended, and Federal Financial Accounting Technical Release (TR) No. 20, as amended. Questions and answers in TR No. 20 provide implementation guidance for applying the requirements of SFFAS No. 54.

Federal Lease Accounting Background

SFFAS No. 54 requires that federal lessees recognize a lease liability and a right-to-use lease asset (also referred to as a lease asset), and that federal lessors recognize a lease receivable and unearned revenues at the commencement of the lease term, unless the lease meets the definitional criteria of a short-term lease, contract or agreement that transfers ownership, or an intra-governmental lease. Lease assets/liabilities (or, for lessors, lease receivables and unearned revenues) are not recognized on the Balance Sheet when accounting for intra-governmental or short-term leases, but normal requirements for prepayments and receivables/payables continue to apply based on the guidance provided in SFFAS No. 1 and SFFAS No. 5.

Per SFFAS No. 54, a lease is a contract or agreement whereby one entity (lessor) conveys the right to control the use of an underlying asset to another entity (lessee) for a period of time specified in a contract or agreement in exchange for consideration. Entities should consider whether the contract conveys the "right to control" the use of the underlying asset by assessing whether the contract or agreement gives the lessee both the right to obtain and the right to control access to the benefits/services of the underlying asset. Under SFFAS No. 54 guidance, leases may include agreements that meet the definition for a lease, even though they are not explicitly identified as leases.

Leases per Procurement/Acquisitions versus Leases per Accounting

The definition of what constitutes a lease may vary depending on the perspectives and bodies of authority a federal organization is applying when managing contracts, agreements, or similar arrangements. Leases have different definitions that may apply to the fields of procurements/acquisitions and legal authorities (which can be unique to a particular federal entity) as well as budgeting.

For some procurements/acquisitions the legal definition of contract/agreement might be “a conveyance to the government of the right of exclusive possession of real property for a definite period of time by a landlord. It may include operation services provided by the landlord” (General Services Acquisition Manual, 570.102).

The proprietary accounting definition as defined by FASAB is conveyance of the right to obtain and control access to economic benefits or services from use of the underlying asset as specified in the contract or agreement in exchange for consideration. The fact that a federal reporting entity may not have leasing authority from a legal perspective does not preclude a contract/agreement from being considered a lease (or containing a lease in a bundled or consolidated procurement) for proprietary accounting recognition purposes.

It is important for entities to complete a comprehensive review of all significant contracts and agreements to identify characteristics of a lease for proprietary accounting recognition, financial reporting, and disclosure requirements. Current contracts (under today’s SFFAS Nos. 5 and 6’s terminology of leases) that may not be considered a capital lease or operating lease could be considered a right-to-use lease under new SFFAS No. 54 guidance. SFFAS No. 54 Par. 2 states that right-to-use leases include contracts or agreements that, although not explicitly identified as leases, meet the definition of a lease. In addition, some operating leases not currently recognized on the Balance Sheet will be required to be recognized as right-to-use lease assets under SFFAS No. 54.

Primary characteristics of leases under SFFAS No. 54 include:

For proprietary accounting purposes, the following are lease exclusions from consideration as a lease but might be considered a lease for procurement/acquisition purposes.

Entities may establish materiality thresholds (similar to capitalization thresholds when accounting for fixed assets) for non intra-intragovernmental, non short-term leases and recognize all such leases at or above the threshold in accordance with SFFAS No. 54. Entities have flexibility in how they account for leases that are below the threshold, which are immaterial both individually and in the aggregate.

Key Entity Decisions for Proprietary Accounting

Classification of intra-governmental leases is straightforward: If a contract or agreement occurring within a federal consolidation entity, or between two or more federal consolidation entities, as defined in SFFAS No. 47, Reporting Entity, and one entity (lessor) conveys the right to control the use of an underlying asset to another entity (lessee) for a period of time specified in a contract or agreement in exchange for consideration, then the contract/agreement is classified as an intra-governmental lease.

When classifying non intra-governmental leases, entity management is responsible for exercising professional judgement and collaborating within its entity to reach certain determinations before establishing lease proprietary accounting treatment, including:

1) Lease Term, with consideration for Options, Renewals/Terminations, and Cancellation Clauses. Calculating the lease term for non intra-governmental leases is pivotal because the classification between short-term leases and right-to-use leases depends on the lease duration. The lease term is determined to be the noncancelable lease period, plus certain periods subject to options to extend or terminate the lease. Entities should carefully review specific provisions from SFFAS Nos. 54, 60, and 61 when determining the lease term. In addition, some specific provisions may also need to be applied when determining the lease term. Please see SFFAS 5, Pars. 14-21 for full guidance on the lease term. Also see Technical Release 20, Pars. 20-31, and Technical Release 22, Pars. 7-8 for specific lease term examples.

2) Calculation of Lease Asset/Liability, with consideration for Fixed vs. Variable Payments. The Lessee’s lease liability and the Lessor’s lease receivable should include the present value of payments expected to be made during the lease term. Generally, these include fixed payments, certain variable payments that are fixed-in-substance or depend on an index or rate, and certain lease incentives. Other variable payments should not be included in the measurement of the lease asset/liability but should be recognized as lease expense/revenue during the reporting period to which they relate. For a complete list of payment types to include in the present value of payments, please see SFFAS 54, Pars. 40 and 56.

3) Selection of Interest Rates for Proprietary Accounting - Amortization of Discount on Lease Liability/Receivable. Future lease payments should be discounted using the interest rate the lessor charges the lessee. When the rate is not stated in the lease, SFFAS No. 61 allows entities flexibility to use a rate based on a recent marketable Treasury security rate, or a historical average interest rate on marketable Treasury securities of a similar maturity to the term of the lease: “If the interest rate is not stated in the lease, the interest rate should be based on the interest rate on marketable Treasury securities at the commencement of the lease term (or at the subsequent financial reporting date), with a similar maturity to the term of the lease.” (SFFAS 61, Par. 6) Entity methodology for selecting interest rates based on marketable Treasury securities should be consistent from period to period and be documented. Entities may find additional information on the interest rates on marketable Treasury securities at: https://www.treasurydirect.gov/marketable-securities/.

4) Modifications, Terminations, and any respective remeasurements. See SFFAS 54, Pars. 80-86.

A short-term lease is a non intra-governmental lease with a term of 24 months or less. Options to renew, options to terminate, and other modifications may significantly affect the calculation of the lease term, and thus impact the appropriate classification of the lease. No short-term leases should be reported on the Balance Sheet, other than the appropriate assets/liabilities for rent paid in advance or for rent due. A lessee should recognize lease payments paid to the lessor as expenses, while the lessor recognizes lease receipts as revenue, based on the payment provisions of the contract and other applicable standards. Rental increases/decreases, lease incentives, and lease concessions associated with short-term leases should be recognized by the lessee and lessor when incurred as increases/reductions to lease rental expense and income.

5) Contracts or Agreements with Both Non-lease and Lease Components

For contracts or agreements containing both non-lease and lease components, in which the purpose of the contract is primarily attributable to the non-lease component(s), entities may elect to apply the practical accommodation in SFFAS No. 62.

This practical accommodation allows for the entity to treat the entire contact (including lease components) as a non-lease contract, and expense/recognize as revenue the lease payments, rather than recognizing both expenses/revenue and lease assets/liabilities following SFFAS No. 54 (see SFFAS No. 62 for complete details on how to make the election, along with certain reporting and disclosure requirements. The transitional accommodation applies only to contracts or agreements that meet both of the criteria within Paragraph 96A).

Entity management must use professional judgement to assess the nature of contracts or agreements to make the most appropriate decision on the primary purpose of the contract. (SFFAS No. 62, Par. 5)

Reporting Entity Procedure/Requirements

 For budgetary accounting of leases, federal reporting entities should continue to follow guidance in OMB Circular No. A-11, Appendix B.

Entity management is responsible for exercising professional judgement and collaborating within its entity to reach certain determinations before establishing budgetary accounting treatment, including:

• Operating vs. Capital Leases (as defined by Appendix B of OMB Circular No. A-11),
• Budgetary Lease Term, with consideration for Cancellation Clauses,
• The Budgetary Interest Rate is selected per OMB Circular No. A-94, Appendix C guidance, and
• Budget Authority and Outlays.

Guidance for identifying budgetary interest rates can be found within OMB Circular No. A-94, Appendix C.

USSGL accounts and updated crosswalks are included in the FY 2025 USSGL TFM Supplement. In addition, lease accounting scenarios can be found at: The U.S. Standard General Ledger - USSGL Implementation Guidance.

Federal reporting entities will be requested to provide the Department of the Treasury with evidence showing reasonable assurance of completeness of their leases under SFFAS No. 54, as amended for the government-wide financial statements.

4735.30—Special Basis of Accounting

SFFAS No. 34, The Hierarchy of Generally Accepted Accounting Principles, establishes what constitutes GAAP for federal reporting entities. SFFAS No. 34 recognizes that some federal component reporting entities prepare and publish financial statements (pursuant to the accounting and reporting standards issued by the FASB) and provides that such financial statements prepared in conformity with accounting standards issued by the FASB also may be regarded as in conformity with GAAP. Per SFFAS No. 47, Reporting Entity, consolidation entities (that is, the consolidated government-wide reporting entity or a consolidated component reporting entity) may consolidate component or sub-component reporting entity financial statements prepared in accordance with FASB GAAP without conversion for any differences in accounting policies among the organizations. As a result, entities reporting in conformity with FASB GAAP, consistent with SFFAS 34, may also report their data to GTAS in conformity with FASB GAAP.

Significant entities that are FASB reporters are required to provide Fiscal Service certain audited information that is necessary for the audit of the government-wide financial statements (see Appendix B). This includes information for Note 5 (Investments), Note 21 (Funds from Dedicated Collections), and Note 36 (Reclassification of Financial Statements Line Items). The information to be provided and the manner of obtaining audit coverage must be determined in consultation with Fiscal Service. Please reference the FY 2025 TFM Year-end Closing Bulletin for guidance on transmission of applicable documents.

Significant entities that are FASB reporters need to also report the information in OMB Circular No. A-136, Section II.3.8.37-Note 36: Reclassification of Financial Statement Line Items. Such information may be reported by the significant reporting entity in (i) its annual financial report within a note to the financial statements, (ii) a limited use audited financial statements that includes the Note 36, or (iii) an audited Note 36 (an audit of a special element). FASB reporters that are utilizing the Balance Sheet illustrated in OMB Circular No. A-136 are not required to produce Note 36 for the Balance Sheet. Significant entities that are FASB reporters with a calendar year-end should provide reclassification information to Fiscal Service with the audit assurance limited to the line items or note disclosures identified by Fiscal Service, as discussed below. The FASB reporting entities will also provide the Department of the Treasury the associated crosswalk used to prepare Note 36. Please see the OMB Circular No. A-136 for complete details.

(1) Significant entities that are currently FASB reporters are:

Note: National Credit Union Administration Share Insurance Fund is presented in conformity with FASAB Standards while the Operating Fund, Central Liquidity Facility, and Community Development Revolving Loan Fund are presented in conformity with FASB Standards.

Significant entities with a year-end other than September 30 (i.e., calendar year-end) are subject to all requirements of this TFM chapter. Significant entities with a calendar year-end will report their September 30 account balances in their GTAS ATB submission in accordance with the GTAS Reporting Window Schedule. This set of data, as of September 30, will be used to populate the reclassified financial statement lines through the USSGL crosswalk. These entities are required to have audit assurance on line items or note disclosures that contribute to the top 99% of the total Financial Report line-item data. These entities will receive a report during the second quarter from the Department of the Treasury, outlining which lines and/or notes are required to have audit assurance as of September 30 each year. Entities must provide Fiscal Service a copy of the independent audit report that includes the results of the audit performed on the material line items and notes disclosures identified by Fiscal Service. This audit report will normally be due by November 15.

(2) Significant entities with a calendar year-end:

4735.40—Parent/Child Reporting

The parent entity (transferor of the appropriation) must report all activity of the child in its financial statements, whether material to the child entity (recipient of the transfer) or not, unless one of the two exceptions (detailed below) applies. The parent entity is the trading partner entity for activity involving these TAS. For more detail on how to report trading partner information, please refer to Appendices 1a and 1b.

The two exceptions to the requirement for parent/child reporting (from OMB Circular No. A-136, revised) are:

In these cases, the receiving entity (child) is responsible for reporting all budgetary and proprietary activity in its financial statements and is the trading partner entity. Please refer to Appendices 1a and 1b for details on reporting trading partner information.

GTAS requires the parent entity and the child entity to agree on which federal entity will report the TAS in the bulk file submission.

4735.50—Reciprocal Categories

A RC is comprised of a set of reclassified financial statement line items that are the reciprocal of each other (for example, accounts payable/accounts receivable). These categories assist in the elimination of federal activity at the government-wide level to prepare the Financial Report. Additionally, these RCs facilitate the reconciliation of activities between federal entities. Please see Appendix 2 for a complete list of RCs and the financial statements to which they relate.

Note: General Fund activities must report via GTAS ATB to be crosswalked to a reclassified financial statement line with a RC 30–48 designation for identifying General Fund activity at the government-wide level.

4735.60—Treaties and Other International Agreements

Treaties and other international agreements may create contingencies requiring recognition (as a liability and expense) or disclosure in the financial statements. As such, all federal entities should consider treaties and other international agreements in the analysis and preparation of the entities' annual financial statements.

Treaties and other international agreements are written agreements between the U.S. and other sovereign states, or between the U.S. and international organizations, governed by international law. The subjects of treaties span the whole spectrum of international relations: peace, trade, defense, territorial boundaries, human rights, law enforcement, environmental matters, and many others. The Department of State (State) developed and continues to manage the Circular 175 Procedure (C-175 Procedure), which outlines the approval process for the negotiation and conclusion of international agreements to which the U.S. will become a party.

As discussed in SFFAS No. 5, “A liability for federal accounting purposes is a probable future outflow or other sacrifice of resources as a result of past transactions or events.” SFFAS No. 5 also states that “The probability of a future outflow or other sacrifice of resources is assessed on the basis of current facts and circumstances. These current facts and circumstances include the law that provides general authority for federal entity operations and specific budget authority to fund programs. If budget authority has not yet been provided, a future outflow or other sacrifice of resources might still meet the probability test if (1) it directly relates to ongoing entity operations and (2) it is the type for which budget authority is routinely provided. Therefore, the definition applies both to liabilities covered by budgetary resources and to liabilities not covered by budgetary resources.”

Per State’s C-175 Procedure, federal entities negotiating and concluding treaties and other international agreements on behalf of the U.S. government are required to indicate whether a proposed treaty or other international agreement embodies a commitment to furnish funds, goods, services, or other measurable future financial obligations beyond or in addition to those authorized in an approved budget; and if so, what arrangements are being planned or carried out by the federal entity concerning consultation with OMB for such commitment. State will not authorize such commitments without confirmation that the relevant budget approved by the President requests or provides funds adequate to fulfill the proposed commitment, or that the President has decided to seek the required funds. All provisions of the C-175 Procedure apply whether a proposed treaty or other international agreement is to be concluded in the name of the U.S. government, or in the name of a particular federal entity of the U.S. government.

For financial reporting purposes, all treaties and other international agreements may be understood as falling into three broad categories:

No Present or Contingent Obligation to Provide Goods, Services, or Financial Support

(no recognition or disclosure)

Treaties and other international agreements under the first category do not result in a liability or contingency when entered into force. Instead, these treaties or other international agreements may establish frameworks that govern cooperative activities, such as aviation safety with other countries, but leave to the discretion of the parties whether to engage in any such activities. In other cases, the agreements may contemplate specific cooperative activities, but create no present or contingent obligations to engage in them. Cooperative activities relevant to these treaties and other international agreements often involve actions that federal entities undertake as part of their regular operations, funded by their regular budgets.

Present Obligation to Provide Goods, Services, or Financial Support

(recognition)

Treaties and other international agreements falling in the second category involve a present obligation, and therefore result in liability recognition. Such present obligation may relate to the U.S. Government providing financial and in-kind support, including assessed contributions, voluntary contributions, grants, and other assistance to international organizations in which it participates as a member. Examples of such agreements include:

Such agreements may not be entered without specific statutory authority to undertake the obligation to spend money. Liabilities arising from such agreements should be recognized for any unpaid amounts due as of the reporting date. The liabilities include amounts due from the federal entity to pay for benefits, goods, or services provided under terms of the agreements, as of the entity’s reporting date, whether such amounts have been reported to the entity. These liabilities may either be fully funded or established against future funding.

Contingent Obligation to Provide Goods, Services, or Financial Support (may require recognition or disclosure)

The last category encompasses treaties or other international agreements which result in contingencies that may require recognition or disclosure in the financial statements. Such contingencies may stem from commitments in a treaty or other international agreement to provide goods, services, or financial support when a future event occurs, or from litigation, claims, or assessments forged by other parties to the agreement. In such instances, conditions, situations, or circumstances exist involving uncertainty as to possible gain or loss to an entity that will ultimately be resolved when one or more future events occur or fail to occur. In accordance with SFFAS No. 5, a contingent liability should be recognized on the face of the basic financial statements when a past event or exchange transaction has occurred, and a future outflow or other sacrifice of resources is probable and measurable. If any of the conditions for liability recognition are not met, and there is at least a reasonable possibility that a loss or an additional loss may have been incurred, a contingent liability should be disclosed in the notes regarded as an integral part of the basic financial statements.

Disclosure should include the nature of the contingency and an estimate of the possible liability, an estimate of the range of possible liability, or a statement that such an estimate cannot be made. For circumstances where the recognition or disclosure of a contingent liability relates to litigation, claims, or assessments resulting from the U.S. Government’s involvement in a treaty or other international agreement, federal entities should summarize the financial treatment of such contingencies (recognition or disclosure) relative to the financial statements in the annual legal letter process. Any legal claim that is related to a treaty or other international agreement should be indicated as such on the legal letter form and in the appropriate column in the entity’s Management Schedule. For a summary of the proper financial treatment of contingent liabilities related to litigation, claims, and assessments, refer to subsection 4745.10—Legal Letter Reporting Requirements.

Federal entity management must determine whether the entity has treaties and other international agreements it is responsible for reporting. If the federal entity has treaties and other international agreements it is responsible for reporting, entity management must:

Direct inquiries and deliver documents required by this chapter to:

Department of the Treasury 
Bureau of the Fiscal Service 
Financial Reports Division 
financial.reports@fiscal.treasury.gov

Also, deliver documents required by this chapter to:

Carolyn Voltz, CPA 
Government Accountability Office 
USCFS@gao.gov

Carol S. Johnson, Policy Analyst 
Office of Management and Budget 
Office of Federal Financial Management 
csjohnson@omb.eop.gov 
MAX.gov

Scott Bell, Senior Staff Accountant 
Department of the Treasury 
Office of the Fiscal Assistant Secretary 
robert.bell@treasury.gov

Legal Counsel Responses:

Department of Justice 
Legal.Letters@usdoj.gov