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not-for-pro t HCOs to separately disclose the beginning and ending accumulated derivative gain or loss that has been excluded from the performance indicator, the related net change associated with current period hedging transactions, and the net amount of any reclassi cations into the performance indicator in a manner similar to that described in paragraph 47 of FASB Statement No 133
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Use of the Short-Cut Method FASB Statement No 138, Accounting for Certain Derivative Instruments and Certain Hedging Activities (an Amendment of FASB Statement No 133), limited application of the shortcut method to interest rate swaps that reference US Treasury rates orLIBOR(London Interbank Offered Rate) as the underlying Many not-for-pro t HCOs use swaps whose underlying is the Bond Market Association Municipal Swap Index (sometimes referred to as the ( BMA ) Index ) Under FASB No 138, the BMA Index does not constitute a benchmark interest rate for purposes of applying the shortcut method Accordingly, if the variable leg of a swap is indexed to the BMA Index (or any rate other than Treasuries or LIBOR), the hedging relationship does not qualify for the short cut method Split-Interest Agreements As discussed at Subsection 363(k)(iii), a split interest agreement is a form of contribution to a not-for-pro t organization in which the not-for-pro t organization must share the bene ts received with other bene ciaries The amount of the bene t to each bene ciary often will be a function of the fair value of the donated assets over the term of the agreement When the reporting not-for-pro t organization directly receives the donated assets (or is trustee over a trust containing the donated assets), the AICPA audit and accounting guide Not-for-Pro t Organizations requires that a liability be recognized for the obligation to make future payments to the other bene ciaries of the trust based on the present value of the future expected payments to the bene ciaries Although that liability may re ect the fair value of the obligation initially, it will not re ect fair value in future periods because the audit guide indicates that the discount rate used in remeasuring the liability each period should not be revised to re ect current interest rates Because the liability is not measured at fair value, the potential for an embedded derivative exists In April 2002, the FASB cleared Derivatives Implementation Group (DIG) Issue No B35, Application of Statement No 133 to a Not-for-Pro t Organization s Obligation Arising from an Irrevocable Split-Interest Agreement Issue No B35 states that the obligation recognized under a split interest agreement should be analyzed to determine whether there is an embedded derivative; if so, the embedded derivative must be separated from its host contract and accounted for separately if certain circumstances are met In situations where the obligation to make payments to other bene ciaries ceases upon the death of the bene ciary(ies), the split-interest agreement is considered to be life contingent and, thus, is excluded from Issue No B35 under the exception provided in paragraph 10(c) of FASB No 133 for insurance arrangements However, under xedperiod arrangements (ie, those where the payments are made for a speci ed number of years), if the payments vary based on the investment return from the contributed assets, bifurcation of an embedded derivative will be required Issue No B35 only addresses split-interest agreements that are irrevocable The author believes that split-interest agreements that are revocable by the donor do not give rise to embedded derivatives under FAS No 133, as both the assets and the corresponding obligations are recognized at fair value For similar reasons, situations in which a not-for-pro t organization holds a split-interest agreement in the capacity of an independent trustee without having any bene cial interest in the arrangement (ie, acting similar to a nancial institution or scal agent) would not appear to be impacted by Issue No B35
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