When recorded at fair value at the reporting date, servicing assets and liabilities are subject to the disclosure requirements of ASC 820, in addition to the disclosures required by ASC 860-50-50 (see FSP 22).

For a hedged item that is reported at fair value or has been in a hedging relationship for changes in its overall fair value from inception such that it is essentially measured at its full fair value, we believe it would be appropriate to apply the disclosure requirements of ASC 820-10-50.

For a hedged item reported on a measurement basis other than fair value (in which the change in overall fair value is not the hedged risk), we do not believe the partial measurement of fair value, achieved through the adjustments of carrying value, requires fair value disclosures for the hedged item as a whole or for the adjustments to the carrying value separately.

Plan assets of a defined benefit pension or other postretirement plan accounted for under ASC 715, Compensation—Retirement Benefits, are excluded from the scope of ASC 820. However, these assets are subject to the disclosures required by ASC 715-20-50-1(d)(iv) for public entities and ASC 715-20-50-5(c)(iv) for nonpublic entities (see FSP 13).

Excess 401(k) plans provide employees with an opportunity to increase savings beyond the limits of the reporting entity’s qualified 401(k) plan. Employee contributions to an excess 401(k) plan are generally part of the general assets of the reporting entity but the amount due to the employee is tracked using a “phantom account.”

We believe reporting entities can make a policy election to measure the phantom account at fair value. If the reporting entity measures the liability at fair value, the disclosures required by ASC 820 are necessary. If it is not measured at fair value, the phantom account is not subject to ASC 820 for measurement or disclosure.

ASC 820 disclosure requirements will apply each time the reporting entity adjusts the recorded amount of the long-lived assets held for sale, as discussed in PPE 5.3.

When a long-lived asset is impaired, the reporting entity should include the nonrecurring measurement disclosures in (1) the quarter in which the impairment was recorded, (2) its subsequent quarterly filings for the year in which the impairment is recorded, and (3) the annual filings that include the quarter in which the charge was recognized. We believe the approach to include the disclosure in subsequent quarterly filings is consistent with the interim disclosure requirements in Rule 10-01 of Regulation S-X. The primary principle in S-X 10-01 is that the financial statement user will have read the prior year's annual financial statements and the quarterly financial statements should include disclosures for significant events that occurred during the current year, such as impairments. Also, because the year-to-date information is included in each quarterly report, an impairment in one quarter would be recognized in the following quarter’s or quarters’ year-t0-date information, and thus disclosure when material would be required.