Figure CA 5-1 summarizes some of the more common presentation and disclosure requirements that should be considered by reporting entities based on the nature of the crypto assets. However, this list is not exhaustive and will need to be tailored to develop disclosures that are specific to the entity and the relevant facts and circumstances.
Figure CA 5-1
Summary of presentation and disclosure requirements for crypto assets
ASC 235, Notes to Financial Statements
Disclosures should include the accounting policies and principles followed in accounting for the crypto assets and the method of applying them.
ASC 275, Risks and Uncertainties
Given the risks and uncertainties associated with certain crypto assets, reporting entities should consider the need for disclosures about the nature of the crypto asset activities they are undertaking, the use of estimates for fair value, and any vulnerabilities due to concentration of risk due to a lack of diversification.
ASC 350-30, Intangibles – Goodwill and Other – General Intangibles Other Than Goodwill
When an impairment is recognized on crypto assets accounted for as intangible assets not in scope of ASC 350-60, include a description of the circumstances leading to the impairment, the amount of the impairment, the caption in the income statement that includes the impairment loss, and the segment in which the impaired asset is reported.
FSP 8.8.1
ASC 350-60, Intangibles – Goodwill and Other – Accounting for and Disclosure of Crypto Assets
In-scope crypto assets are required to be presented separately from other intangible assets on the balance sheet. Remeasurement of those crypto assets is required to be recorded separately from amortization or impairment of other intangible assets in the income statement. Additional disclosures are required, including significant crypto asset holdings and a reconciliation of the beginning and ending balances of crypto assets
ASC 606, Revenue from Contracts with Customers
To the extent the crypto transaction is classified as a sale to a customer, include the relevant revenue disclosures, tailoring as appropriate based on whether the entity is a principal or agent.
ASC 820, Fair Value Measurement
When the crypto asset is a financial asset, include the relevant disclosures for an instrument that is recorded at fair value on a recurring basis.
For crypto assets that are recognized as intangible assets not in scope of ASC 350-60, include the fair value disclosure for assets recorded at fair value on a non-recurring basis.
For crypto assets that are recognized as intangible assets in scope of ASC 350-60, include the fair value disclosure for assets recorded at fair value on a recurring basis.
For reporting entities in scope of SAB 121 that are required to recognize a crypto asset safeguarding liability and corresponding asset, include the fair value disclosure for liabilities and assets recorded at fair value on a recurring basis, respectively.
FSP 20

CA 5.2

CA 5.4.2
ASC 855, Subsequent Events
Reporting entities may need to disclose significant subsequent events related to crypto assets, such as significant changes in the value of the crypto assets after period end or significant changes in the amount or nature of the crypto asset transactions.
SAB 121 requires disclosures detailing the nature and amount of crypto assets the reporting entity is responsible for safeguarding for its customers.
AICPA’s Digital Assets Practice Aid
Question 25 of the AICPA’s Digital Assets Practice Aid provides examples of disclosures that may be applicable to the lender in a crypto lending arrangement.
Additional considerations for SEC registrants
Regulation S-X Article 5 requires registrants to separately state each class of intangible asset that is in excess of 5% of total assets. The amount of significant additions or deletions related to these assets should be disclosed in a footnote.
Registrants should also consider additional disclosures outside of the financial statements, including any material information that may be necessary to ensure the financial statements are not misleading. In meeting their disclosure obligations, registrants should consider disclosures related to the description of the business, risk factors, and management’s discussion and analysis. For additional information and illustrative examples of comments, refer to the SEC’s Sample Letter to Companies Regarding Recent Developments in Crypto Asset Markets.
Regulation S-X Article 5-02

Securities Act Rule 408 and Exchange Act Rule 12b-20
Note about ongoing standard setting
In December 2023, the AICPA Assurance Services Executive Committee issued an exposure draft, Proposed criteria for the presentation of the sufficiency of assets for redemption: Specific to asset-backed fiat-pegged tokens, to propose criteria for the reporting on the sufficiency of assets for redemption (e.g., cash, cash equivalents, other assets) specific to asset-backed tokens pegged to a fiat currency (commonly referred to as “stablecoins”). The exposure draft addresses three primary topics along with related disclosures:
  • Issuer’s redeemable tokens outstanding
  • Redemption assets available to redeem tokens outstanding
  • Comparison of the balance of redemption assets available to redeem tokens and the issuer’s redeemable tokens outstanding

Comments on the proposed framework are due by January 29, 2024. Financial statement preparers and other users of this publication are therefore encouraged to monitor the status of the project, and if finalized, evaluate the effective date of the new guidance and the disclosure implications.
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