Preparing for GASB 84 – Fiduciary Activities
GASB Statement No. 84, Fiduciary Activities, is effective for fiscal years beginning January 1, 2019.
Impacts: GAAP Governments and CASH Governments
The new standard applies not only governments that report under generally accepted accounting principles, but those that report using the cash-basis accounting model as well.
Implementation of the standard can be time consuming because governments may have fiduciary activities currently being reported in non-fiduciary funds as well as activities that are currently being reported in fiduciary funds that should be reported elsewhere. This could result in fund structure changes as well as changes to annual financial reports and potentially other reporting, policies, and responsibilities.
Where do I start?
Staff with financial reporting responsibilities should start by reading GASB 84 itself, which is found at the GASB website, or by using the link below.
While the statement contains only 28 paragraphs, this pronouncement covers a lot of ground that accounting staff must consider, such as component units, pension and OPEB arrangements, and other activities that are fiduciary in nature, as well as how to report these activities in the financial statements.
Paragraphs 11 through 13 require special consideration, as we believe this is where most governments might mistakenly interpret the criteria and incorrectly identify fiduciary activities.
Additionally, review the Exposure Draft, Proposed Implementation Guide, Fiduciary Activities, which is found at the GASB website, or by using the link below. Note, this is a draft of the implementation guidance that will be provided by GASB. This draft provides questions submitted to GASB by governments along with the GASB responses.
Discuss the Standard
Brainstorm about potential operations that may fit the definition of fiduciary activities, whether currently reported in an agency fund or not.
Don’t rely solely on accounting and finance staff; rather, actively seek input from across organizational lines, involving department heads and midlevel management to gain a solid understanding the nature of potential fiduciary activities. You might need to involve third party service providers such as your OPEB plan administrator.
Review Accounts, Transactions, and Funds
A member of the accounting staff should review general ledger accounts for fiduciary activities that might not be obvious. Special attention should be paid to liability accounts, revenue accounts with frequent or significant debit transactions, and miscellaneous accounts. If you identify potential fiduciary activities, you should evaluate further with those most knowledgeable about the activity.
Also, review the activities already reported as agency funds to determine if they will remain in fiduciary funds or if the activities will need to be reported elsewhere.
Plan Fund Structure Changes
Once your research is complete, you most likely will need to make some changes.
Establish a plan to modify your agency fund structure to align with the four types of fiduciary funds as defined by GASB 84, including formal action by your governing body if required.
Adjust accounting procedures to ensure fiduciary transactions are reported according to the specific guidance found in GASB 84. For example, you might need to change your procedures so that a liability to beneficiaries is only reported once an event has occurred to require a disbursement of assets.
Consider Broader Implications
Beyond just preparing for accurate annual financial reporting, spend some time considering other aspects of financial operations that may need attention. For example, monthly reporting to department heads and the governing body might need adjustment and could require additional explanation about the changes to those impacted. Budgeting processes might be affected, because resources and transactions might no longer be accounted for in their traditional funds.
In certain circumstances, organizational changes might be needed for officials with responsibility for fiduciary activity to maintain that responsibility regardless of where the activity is reported.
The GASB has issued the draft implementation guide (discussed above). This guide is open for comments to GASB until February 28, 2019. GASB will evaluate comments and issue the final version of the implementation guide in 2019.
The BARS Manual provides information on the new definitions for fiduciary fund types and new financial statement examples.
We encourage governments to use our Help Desk to share any questions or concerns they identify with the new standard during their research.
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