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After a reporting entity has discontinued application of rate-regulated accounting, facts and circumstances may change such that ASC 980 should be reapplied. For example, a reporting entity may discontinue rate-regulated accounting due to uncertainty during a long rate freeze period. However, it may subsequently conclude that it is appropriate to reapply ASC 980 as a result of a return to full cost-based regulation. Such reapplication is accounted for as a change in application of an accounting principle as a result of changed circumstances. There are several accounting implications for regulated utilities that reapply regulatory accounting to all or a separable portion of the business, as highlighted in Figure UP 17-8.
Figure UP 17-8
Impact of reapplication of ASC 980
Impact
Considerations
Record amounts that meet the definition of regulatory assets and liabilities
The carrying amounts of other assets and liabilities generally should not be adjusted, even if their carrying amounts may have been different had rate-regulated accounting never been discontinued.
Start recording AFUDC (allowance for funds used during construction) if it is probable of future recovery (see UP 18.3)
Plant balances should not be adjusted for any difference that resulted from capitalizing interest under ASC 835 instead of AFUDC while rate-regulated accounting was discontinued.
Record assets for previously disallowed incurred costs that are subsequently allowed by a regulator, consistent with classification if costs had been initially allowed
Reverse any impairment losses that were previously recorded under ASC 360 in connection with adopting ASC 980-20, if such amounts become probable of recovery as a result of a specific regulator action. See UP 18.7 for further information on regulatory accounting for impairment losses.
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