ASC 815 (as amended by ASU 2017-12) also provides private companies (that are not financial institutions or certain not-for-profit entities) with extra time to complete some of the hedge documentation for hedging relationships other than those accounted for using the simplified hedge accounting approach. Unlike the documentation deferral for the simplified hedge accounting approach (under which all of the documentation can be deferred), documentation for hedges accounted for using another method are split between items that must be documented at hedge inception and others that can be deferred until the next interim (if applicable) or annual financial statements are available to be issued.
The following table summarizes the timing of documentation requirements discussed in ASC 815-20-25-139 and ASC 815-20-25-140.
To be documented at inception of the hedging relationship
To be documented before the financial statements are available to be issued
• The hedging relationship
• The hedging instrument
• The hedged item
• The nature of the risk being hedged
• The method of assessing hedge effectiveness at inception and on an ongoing basis
• Initial hedge effectiveness assessments
Private companies are still required to complete multiple assessments of effectiveness. For example, four assessments must be completed for every hedge outstanding for the entire year. This is because the purpose of the assessments is to validate that the application of hedge accounting was appropriate for the entire annual period. In addition, the effectiveness assessments must be done using relevant data as of hedge inception and each subsequent quarter-end, regardless of when they are performed.
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