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Most requirements for reporting and disclosing derivatives are applicable to both public and nonpublic reporting entities. Only one set of requirements, the accounting policy disclosures in Regulation S-X Rule 4-08(n), are not applicable to private companies. However, two of the accounting policy disclosures in Regulation S-X have similar requirements under ASC 815 that are applicable to private companies, as noted in FSP 19.5.2A.
Also, there is one election that simplifies hedge accounting for private companies in certain cases.

19.6.1 Private company alternative — hedge accounting

Private companies that are not financial institutions may elect a hedge accounting alternative (a simplified hedge accounting approach) for certain types of swaps that economically convert a variable-rate borrowing into a fixed-rate borrowing. This simplified approach is available when all six qualifying conditions within ASC 815-20-25-131D are met.
The simplified approach allows a private company to measure a designated swap at settlement value rather than at fair value. The disclosures for fair value measurements required by ASC 820 are still required for amounts disclosed at settlement value. Disclosures related to swaps measured at settlement value should be clearly designated separate from the fair value disclosures. All of the presentation and disclosure requirements of ASC 815 continue to apply. When a private company uses the simplified approach to hedge accounting, disclosure of settlement value is required. See FSP 20 for information on the disclosures for fair value measurements.
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