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ASC 960-325-35-1 requires defined benefit pension plans to report all investments (excluding insurance contracts and fully benefit-responsive investment contracts) at fair value. ASC 960-325-35-3 requires defined benefit pension plans to report insurance contracts in the manner prescribed by Form 5500 (i.e., contract value).
ASC 962-325-35-5 requires defined contribution plans, including health and welfare and pension plans, to report all investments (excluding insurance contracts and fully benefit-responsive investment contracts) at fair value.
See PEB 9.6.1 for information about insurance contracts and PEB 9.6.2 for information about fully benefit-responsive investment contracts.
ASC 820, Fair Value Measurements and Disclosures, defines fair value, establishes a framework for measuring fair value, and requires disclosures about fair value measurements. Refer to PwC's Fair value measurements guide for further guidance on fair value measurements.
Employee benefit plans that are not subject to SEC filing requirements (i.e., they do not file a Form 11-K) can indefinitely defer the requirement to provide quantitative disclosures of the significant unobservable inputs used in fair value measurement solely of investments held by the employee benefit plan in its plan sponsor's own nonpublic equity securities, including equity securities of its plan sponsor’s nonpublic affiliated entities.
Employee benefit plans are exempt from the requirements of ASC 820-10-50-2B(a) to disaggregate assets by nature, characteristics, and risk. The disclosure of information required by ASC 820-10-50 are provided by general type consistent with ASC 960-325-45-2, ASC 962-325-45-5, and ASC 965-325-45-2.

9.6.1 Direct investments in fully benefit-responsive contracts

Insurance contracts, as described in ASC 944-20, are required to be presented in the same manner as specified in the annual report filed by the plan with certain governmental agencies as required by ERISA; that is, either at fair value or at an amount determined by the insurance entity (contract value).

9.6.2 Fully benefit-responsive investment contracts held by benefit plans

Fully benefit-responsive investment contracts are measured at contract value. An investment contract is considered fully benefit-responsive if all of the criteria in ASC 962-325-20 are met for that contract, analyzed on an individual basis. The criteria are:
  • The investment contract is effected directly between the plan and the issuer, and prohibits the plan from assigning or selling the contract or its proceeds to another party without the consent of the issuer.
  • Either (1) the repayment of principal and interest credited to participants in the plan is a financial obligation of the issuer of the investment contract or (2) prospective interest crediting rate adjustments are provided to participants in the plan on a designated pool of investments held by the plan or the contract issuer whereby a financially responsible third party, through a contract generally referred to as a wrapper, must provide assurance that the adjustments to the interest crediting rate will not result in a future interest crediting rate that is less than zero. If an event has occurred such that realization of full contract value for a particular investment contract is no longer probable (for example, a significant decline in creditworthiness of the contract issuer or wrapper provider), the investment contract would no longer be considered fully benefit-responsive.
  • The terms of the investment contract require all permitted participant-initiated transactions with the plan to occur at contract value with no conditions, limits, or restrictions. Permitted participant-initiated transactions are those transactions allowed by the underlying defined contribution plan, such as withdrawals for benefits, loans, or transfers to other investment options within the plan.
  • An event that limits the ability of the plan to transact at contract value with the issuer (for example, premature termination of the contracts by the plan, plant closings, layoffs, plan termination, bankruptcy, mergers, and early retirement incentives) and that also limits the ability of the plan to transact at contract value with the participants in the plan must be probable of not occurring.
  • The plan itself must allow participants reasonable access to their funds.
ASC 962-205-45-6 requires the statement of changes in net assets available for benefits to be prepared on a basis that reflects income credited to participants in the plan and net appreciation or depreciation in the fair value of only those investment contracts that are not deemed to be fully benefit responsive.
As outlined in ASC 962-325-50-3, defined-contribution plans, including both health and welfare, and pension plans are required to disclose the following in connection with fully benefit-responsive investment contracts, in the aggregate:
  • A description of the nature of those investment contracts (including how they operate) by type.
  • A description of the events that limit the ability of the plan to transact at contract value with the issuer (for example, premature termination of the contracts by the plan, plant closings, layoffs, plan termination, bankruptcy, mergers, and early retirement incentives), including a statement that the occurrence of each of those events that would limit the plan’s ability to transact at contract value with participants in the plan is not probable of occurring.
  • A description of the events and circumstances that would allow issuers to terminate fully benefit-responsive investment contracts with the plan and settle at an amount different from contract value.
  • The total contract value of each type of investment contract (for example, synthetic investment contracts or traditional investment contracts).

9.6.2.1 Indirect investments in fully benefit-responsive contracts

Some plans indirectly invest in fully benefit-responsive investment contracts through holdings in a collective trust (CCT) (or similar vehicle). CCTs are reported in the plan’s financial statements at fair value, often using the net asset value (NAV) (or its equivalent) practical expedient, in a manner consistent with the measurement principles of ASC 946. NAV represents the plan’s fair value since this is the value at which the plan transacts with the CCT.

9.6.3 Separate account investments held by benefit plans

A separate account is an account established by an insurance entity solely for the purpose of investing assets of one or more employee benefit plans. The assets of a separate account are assets of the insurance company but are not commingled with the insurance company's general assets.
A separate account in which several plans participate is generally referred to as a pooled separate account, with each plan's share of a pooled separate account determined on a participation-unit or variable-unit basis.
A separate account in which only one plan participates is generally referred to as an individual separate account or as a separate-separate account. These assets are not commingled with assets of the insurer or other plan sponsors.
Separate accounts that calculate a net asset value (NAV) per participation unit are valued under ASC 820-10-15-4 through ASC 820-10-15-5. For separate accounts that do not calculate NAV per share, for purposes of determining valuation, it is appropriate to look through to the underlying investments in the account. For some separate accounts, typically those providing a guaranteed rate of return, contract value may be the best evidence of fair value.
Plans may invest in an investment contract issued by an insurance company that will generate returns based on the performance of underlying or reference assets (e.g., pooled accounts). In these situations, plan management may determine that the appropriate unit of account is the investment contract rather than the underlying investments. Alternatively, some investment contracts require that the underlying assets be maintained in a "separate account" of the insurance company, and sometimes plan management has some involvement in investment decisions relating to the separate account. These assets are generally not commingled with assets of the insurer or other plan sponsors, and while the insurer legally owns the assets, they may not be available to its general creditors in bankruptcy. Accordingly, it may be appropriate to look through the separate account to use the underlying investments as the unit of account.

9.6.4 Benefit plan master trust investments

A master trust holds assets of more than one plan sponsored by one employer or by a group of employers under common control. A master trust is a vehicle that receives cash, invests it, liquidates investments, and has neither rights to contributions nor obligations to pay benefits, as these rights and obligations belong to the plans that participate in the master trust. Therefore, receivables (and payables) that relate specifically to the master trust (such as an interest receivable for bonds in the master trust) should be reported at the master trust level and not the plan level. Similarly, receivables (and payables) that relate specifically to the underlying plans in the master trust (such as a contribution receivable) should be reported at the plan level, and not at the master trust level. Accrued expenses should receive similar treatment, with a facts and circumstances analysis to determine whether an item relates to the master trust or the underlying plans, thereby determining its presentation in the financial statements. Generally, investment-related expenses (e.g., trustee fees, custodial fees) are recorded at the master trust level and specific plan-related expenses (e.g., actuary fees, legal fees) are recorded at the plan level.
Plans participating in a master trust are required to disclose the percentage of the plan’s interest in each type of investment, other assets, and liabilities of the master trust.

9.6.5 Securities lending by a benefit plan

Securities lending is the temporary loan of a security from one financial institution to another to earn additional income. Plans that engage in securities lending should present the assets received in return for the securities (collateral), as well as the exchanged securities, on the statement of net assets available for benefits. The exchanged securities, as well as the assets received for them (if an investment), should be reported on the supplemental schedule of assets (held at end of year) required by ERISA with the appropriate disclosures. A liability should be recorded on the statement of net assets available for benefits for the return of the collateral. See PEB 9.10.1 for discussion of supplemental schedules required by ERISA.
For securities lending arrangements within a master trust, note disclosure of the master trust investments should include the collateral received, as well as an offsetting liability for the return of the collateral. Since plan investments in a master trust are recorded as a single line item on the plan’s statements of net assets, securities lending in the master trust would not be reflected on the face of the plan’s financial statements.
See AAG-EBP Chapter 8 and ASC 860 for additional information regarding securities lending.
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