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Statement of Federal Financial Accounting Standards 29:
Heritage Assets and Stewardship Land
Status
Summary
This standard changes the classification of information reported for heritage assets and
stewardship land provided by Statement of Federal Financial Accounting Standards 8. This
standard reclassifies all heritage assets and stewardship land information as basic information.
This standard requires that entities reference a note on the balance sheet that discloses
information about heritage assets and stewardship land, but no asset dollar amount should be
shown. Instead, the note disclosure provides minimum reporting requirements consistent with
the previous standards for heritage assets and stewardship land. These requirements include a
description of major categories, physical unit information for the end of the reporting period,
physical units added and withdrawn during the year, and a description of the methods of
acquisition and withdrawal.
This standard also requires two new disclosures for heritage assets and stewardship land.
Specifically, this standard requires additional reporting disclosures about entity stewardship
policies and an explanation of how heritage assets and stewardship land relate to the mission of
the entity.
This standard also includes the requirements for the U.S. Government-wide Financial Statement.
It provides for a general discussion and directs users to the applicable entities’ financial
statements for more detailed information on heritage assets and stewardship land.
Issued July 7, 2005
Effective Date For reporting periods beginning after September 30, 2005, with the
exception of the specific paragraphs listed in par. 43 of the standard.
Full implementation of the standards is effective for periods
beginning after September 30, 2008.
Affects SFFAS 6
SFFAS 8
SFFAS 14
SFFAS 16
Affected by SFFAS 42 affects paragraphs 26, 28, 41 and 42.
SFFAS 59 transitionally amends paragraphs 33, 35, 39 and 42;
rescinds and replaces paragraph 40 and inserts new paragraphs
36A-36D, 40A and 42A.
Related Guidance TR 9, Implementation Guide for SFFAS 29
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This standard amends several existing standards. The amendments rescind certain standards or
parts of certain standards due to the classification change, as well as serve as a means to
incorporate all standards specific to heritage assets and stewardship land into one document.
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Table of Contents
Summary 1
Introduction 4
Standards of Federal Financial Accounting 5
Heritage Assets (including Multi-use Heritage Assets) 5
Stewardship Land 10
Effective Date 16
Appendix A: Basis for Conclusions 18
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Introduction
1. The required supplementary stewardship information (RSSI) category, as described in
Statement of Federal Financial Accounting Standards (SFFAS) 8, was a response to the
unique aspects of the Federal accounting and reporting environment, and to the broad
objectives of Federal financial reporting. It was intended to permit flexibility on the part of
preparers and auditors that would facilitate reporting relevant, reliable information, including
nonfinancial and nonhistorical information.
1
2. Although some stewardship information may not link directly with the basic financial
statements because the data to be reported may be other than in dollar terms, the Federal
Accounting Standards Advisory Board (the Board or FASAB) intended that RSSI information
would augment the basic financial statements and would receive commensurate audit
scrutiny.
3. The Board found, however, that in many cases the word “supplementary” in the RSSI title
caused certain readers to assume that the information was of secondary importance. Since
this was contrary to its intentions, the Board decided to eliminate the RSSI category and re-
categorize the stewardship elements within the reporting categories that are well defined in
existing professional literature and familiar to report users. Additionally, this standard
clarifies the Board’s expectation that information essential to fair presentation will be subject
to audit.
4. The main focus of this standard is the reclassification of heritage assets and stewardship
land information. This standard reclassifies heritage assets and stewardship land
information as basic information. Specifically, this standard requires that entities reference a
note on the balance sheet that discloses information about heritage assets and stewardship
land, but no asset dollar amount should be shown. The note disclosure provides minimum
reporting requirements consistent with the previous standards for heritage assets and
stewardship land, which includes a description of major categories, physical unit information
for the end of the reporting period, physical units added and withdrawn during the year, and
a description of the methods of acquisition and withdrawal.
1
See the Implementation Guide to Statement of Federal Financial Accounting Standards 7: Accounting for Revenue
and Other Financing Sources, par. 22-24, the diagram on page 15, and minutes of associated Board discussions. See
also SFFAS 8, Supplementary Stewardship Reporting, par. 21, 34, 111-115, and minutes of associated Board
discussions.
2
[Deleted.]
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5. Although the most significant change within this standard is this reclassification, it also
introduces certain changes to the disclosure requirements for heritage assets and
stewardship land. Specifically, the standard requires additional reporting disclosures about
entity stewardship policies and an explanation of how heritage assets and stewardship land
relate to the mission of the entity.
6. This standard also includes disclosure requirements applicable to the U.S. Government-
wide Financial Statement. This financial statement must provide a general discussion of
heritage assets and stewardship land and direct users to the applicable entities’ financial
statements for more detailed information on these assets.
7. This standard also amends several existing standards. The amendments rescind certain
standards or parts of certain standards due to the classification change, as well as serve as
a means to incorporate all standards specific to heritage assets and stewardship land into
one document.
8. The Board believes by fully incorporating into this standard all requirements for heritage
assets (including multi-use heritage assets) and stewardship land, readers will better
understand all reporting requirements. However, the main issues deliberated by the Board
were the reclassification and presentation of heritage assets and stewardship land
information. The Board has not reconsidered the definition, recognition and measurement
provisions of the existing standards. These provisions have been brought forward from
those standards that were based on prior Boards’ conclusions.
9. The Board developed this standard for heritage assets and stewardship land based on the
importance of the data in meeting the stewardship reporting objective as described in
Statement of Federal Financial Accounting Concepts (SFFAC) 1, Objectives of Federal
Financial Reporting. Further information on the Board’s considerations regarding this
reclassification is included in the Basis for Conclusions.
Standards of Federal Financial Accounting
Heritage Assets (including Multi-use Heritage Assets)
Amendments to Existing Standards
10. SFFAS 6 par. 21 is amended as follows:
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The following paragraphs provide recognition and measurement principles, and disclosure
requirements for general PP&E. For standards relating to heritage assets, multi-use
heritage-assets and stewardship land, see SFFAS 29, Heritage Assets and Stewardship
Land. each category of PP&E. The categories identified are:
general PP&E (including land acquired for or in connection with other general PP&E),
National Defense PP&E,
heritage assets, and
stewardship land (i.e., land not included in general PP&E).
11. SFFAS 6 par. 57 through 65 are rescinded.
12. SFFAS 8 Chapter 2 (Heritage Assets) is rescinded in its entirety.
13. SFFAS 14 par. 10 and 11 are rescinded.
14. SFFAS 16 is rescinded in its entirety.
Definitions
15. Heritage assets are property, plant and equipment (PP&E) that are unique for one or more
of the following reasons:
historical or natural significance,
cultural, educational, or artistic (e.g., aesthetic) importance; or
significant architectural characteristics.
Heritage assets consist of (1) collection type heritage assets, such as objects gathered and
maintained for exhibition, for example, museum collections, art collections, and library
collections; and (2) non-collection-type heritage assets, such as parks, memorials,
monuments, and buildings.
16. Heritage assets are generally expected to be preserved indefinitely. One example of
evidence that a particular asset is heritage in nature is that it is listed on the National
Register of Historic Places.
17. Some investments in heritage assets (e.g., national parks) will meet the definitions and be
considered and reported as both heritage assets and stewardship land (see Stewardship
Land below). Such reporting would not be considered duplication, as the type of information
reported for the physical unit would be different for each category of stewardship asset.
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18. Heritage assets may in some cases be used to serve two purposes—a heritage function
and general government operations. In cases where a heritage asset serves two purposes,
the heritage asset should be considered a multi-use heritage asset if the predominant use
of the asset is in general government operations (e.g., the main Treasury building used as
an office building). Heritage assets having an incidental use in government operations are
not multi-use heritage assets; they are simply heritage assets.
Recognition and Measurement
Heritage Assets
19. With the exception of multi-use heritage assets (addressed in par. 22) the cost of
acquisition, improvement, reconstruction, or renovation of heritage assets should be
recognized on the statement of net cost for the period in which the cost is incurred. The
cost
3
should include all costs incurred during the period to bring the item to its current
condition (See par. 26 of SFFAS 6 for examples of the costs to be considered).
20. With the exception of multi-use heritage assets (addressed in par. 23) no amounts for
heritage assets acquired through donation or devise
4
should be recognized in the cost of
heritage assets.
5
21. With the exception of multi-use heritage assets (addressed in par. 24) transfers of heritage
assets from one Federal entity to another do not affect the net cost of operations or net
position of either entity. However, in some cases, assets included in general PP&E may be
transferred to an entity for use as heritage assets. In this instance, the transferring entity
should recognize a transfer-out of capitalized assets.
6
Multi-use Heritage Assets
22. The cost of acquisition, improvement, reconstruction, or renovation of multi-use heritage
assets should be capitalized as general PP&E and depreciated over its estimated useful life.
3
For a full discussion of cost, including full cost, direct cost and indirect cost, see SFFAS 4, Managerial Cost
Accounting Concepts and Standards for the Federal Government. Also, see par. 94-95, SFFAC 2, Entity and Display.
4
A will or clause of a will disposing of property.
5
SFFAS 7, Accounting for Revenue and Other Financing Sources, par. 258-259 explains that stewardship PP&E is
“expensed if purchased, but no amount is recognized if it is received as a donation.”
6
SFFAS 7, Accounting for Revenue and Other Financing Sources, par. 74 and par. 345-346.
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23. Multi-use heritage assets acquired through donation or devise should be recognized as
general PP&E at the assets' fair value at the time received, and the amount should also be
recognized as "nonexchange revenues" as defined in SFFAS 7, Accounting for Revenue
and Other Financing Sources.
24. Transfers of multi-use heritage assets from one Federal entity to another are transfers of
capitalized assets. The receiving entity should recognize a transfer-in as an additional
financing source and the transferring entity should recognize a transfer-out. The value
recorded should be the transferring entity’s book value of the multi-use heritage asset. If the
receiving entity is not provided the book value, the multi-use heritage asset should be
recorded at its estimated fair value
7
.
Disclosures and Required Supplementary Information
25. Entities with heritage assets should reference a note
8
on the balance sheet that discloses
information about heritage assets, but no asset dollar amount should be shown
9
. The note
disclosure related to heritage assets should provide the following:
a. A concise statement explaining how they relate to the mission of the entity.
b. A brief description of the entity’s stewardship policies for heritage assets. Stewardship
policies for heritage assets are the goals and principles the entity established to guide its
acquisition, maintenance, use, and disposal of heritage assets consistent with statutory
requirements, prohibitions, and limitations governing the entity and the heritage assets.
c. A concise description of each major category of heritage asset. The appropriate level of
categorization of heritage assets should be meaningful and determined by the preparer
based on the entity’s mission, types of heritage assets, and how it manages the assets.
d. Heritage assets should be quantified in terms of physical units. The appropriate level of
aggregation and physical units
10
of measure for each major category should be meaningful
7
See SFFAS 7, Accounting for Revenue and Other Financing Sources, par. 74 for a discussion of transfers of assets.
8
This standard does not prescribe a specific reference or line item entitled “Heritage Assets” as it may be included with
other items for which no dollar amounts are recognized (such as stewardship land and other items that in the future
may require similar non-financial disclosure) for presentation. Instead, the standard allows entities flexibility in
determining the best presentation.
9
No asset dollar amount is shown, except for multi-use heritage assets, which are capitalized and reported as part of
general PP&E. See par. 22 through 24 and par. 27 for additional explanation.
10
Defining physical units as individual items to be counted is neither required nor prohibited. Particularly for collection-
type heritage assets, it may be more appropriate to define the physical unit as a collection, or a group of assets located
at one facility, and then count the number of collections or facilities.
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and determined by the preparer based on the entitys mission, types of heritage assets, and
how it manages the assets. For each major category of heritage asset (identified in c.
above) the following should be reported:
1. The number of physical units by major category; major categories should be
classified by collection or non-collection type heritage assets for which the entity is the
steward as of the end of the reporting period;
2. The number of physical units by major category that were acquired and the number
of physical units by major category that were withdrawn during the reporting period;
and
3. A description of the major methods of acquisition and withdrawal of heritage assets
during the reporting period. This should include disclosure of the number of physical
units (by major category) of transfers of heritage assets between Federal entities and
the number of physical units (by major category) of heritage assets acquired through
donation or devise, if material. In addition, the fair value of heritage assets acquired
through donation or devise during the reporting period should be disclosed, if known
and material.
26.
11,12
Entities should include a reference to deferred maintenance and repairs information
13
reported in required supplementary information.
27. Entities should disclose that multi-use heritage assets are recognized and presented with
general PP&E in the basic financial statements and that additional information for the multi-
use heritage assets is included with the heritage assets information.
U.S. Government-wide Financial Statement Disclosures
14
28. The U.S. Government-wide financial statement should reference a note on the balance
sheet that discloses information about heritage assets, but no asset dollar amount should be
shown. The note disclosure related to heritage assets should provide the following:
11
Footnote deleted by SFFAS 42.
12
Footnote deleted by SFFAS 42.
13
See SFFAS 42, Deferred Maintenance and Repairs, Amending Statements of Federal Financial Accounting
Standards 6, 14, 29 and 32 for information regarding definition, measurement and required supplementary information.
14
SFFAS 24, Selected Standards for the Consolidated Financial Report of the United States Government, clarified that
all existing and future standards apply to all Federal entities, including the U.S. Government-wide Financial Statement,
unless a standard specifically provides otherwise.
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a. A concise statement explaining how they relate to the mission of the Federal
Government.
b. A description of the broad categories of heritage assets of the Federal Government.
c. A general reference to agency reports for additional information about heritage assets,
such as agency stewardship policies for heritage assets, physical units by major categories
of heritage assets.
29. The U.S. Government-wide financial statement should disclose that multi-use heritage
assets are recognized and presented with general PP&E in the basic financial statements
and that additional information for the multi-use heritage assets is included with the heritage
assets information.
Stewardship Land
Amendments to Existing Standards
30. SFFAS 6 par. 66 through 76 are rescinded.
31. SFFAS 8 Chapter 4 (Stewardship Land) is rescinded in its entirety.
32. SFFAS 14 par. 10 and 11 are rescinded.
Definitions
33. Stewardship Land includes both public domain
14.1
and acquired land and land rights
15
owned
by the Federal Government i
ntended to be held indefinitely. Examples of stewardship land
include land reserved, managed, planned, used, or acquired for
16
14.1
Public domain land is land that was originally ceded to the United States by treaty, purchase, or conquest in
contrast to acquired lands, which have been purchased by, given to, exchanged with, or transferred through
condemnation proceedings to the federal government.
15
Land rights are interests and privileges held by the entity in land owned by others, such as leaseholds, easements,
water and water power rights, diversion rights, submersion rights, rights-of-way, mineral rights, and other like interests
in land. Land rights such as easements or rights-of-way that are for an unspecified period of time or unlimited duration
are considered permanent land rights. Temporary land rights are those land rights that are for a specified period of time
or limited duration.
16
Land used or acquired for or in connection with items of general PP&E but meeting the definition of stewardship land
should be classified as stewardship land.
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a. forests and parks;
b. recreation and conservation;
c. wildlife habitat and grazing;
d. historic landmarks and/or the preservation of pre-historic and historic structures
(those listed on or eligible for listing on the National Register of Historic Places);
e. multiple purpose ancillary revenue generating activity (for example, special use
permits, mineral development activities, and timber production); and/or
f. buffer zones for security, flood management, and noise and view sheds.
34. “Land” is defined as the solid part of the surface of the earth. Excluded from the definition
are the natural resources (that is, depletable resources, such as mineral deposits and
petroleum; renewable resources, such as timber; and the outer-continental shelf resources)
related to land.
17
35. Land and land rights meeting the definition of general PP&E established in SFFAS 6, as
amended, should be accounted for in accordance with SFFAS 6, as amended.
36. Land and land rights owned by the Federal Government and not acquired for or in
connection with items of general PP&E should be reported as stewardship land.
36A. Acres of land held for disposal or exchange
include land for which the entity has satisfied
the statutory disposal authority requirements specific to the land in question.
17.1
Disposal
includes conveyances of federal land to non-federal entities not limited to sale, transfer,
exchange, lease, public-private partnership, and donation, or any combination thereof.
36B. Commercial use land sub-category
includes land or land rights that are predominantly used
to generate inflows of resources (such inflows may be derived from the land itself or
activities performed on the land and regardless of whether the use or activity is intended to
produce a profit) from non-federal third parties, usually through special use permits, right-of-
17
The Board presently has an active project to address standards for natural resources, for which the Board is
considering developing individual standards for each type of natural resource separately. To begin the project, the
Board will be addressing oil and gas resources. The framework for the oil and gas resource phase of the project will be
used as a model when addressing the other types or logical sets of natural resources (e.g., timber, grazing land, solid
leasable minerals) in subsequent phases of the project.
17.1
Entity decisions to identify and classify land as held for disposal or exchange often require public participation and
diverse clearances, such as environmental and economic impact studies, surveys, and appraisals.
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way grants, and leases. Such inflows may arise from exchange or non-exchange activities
and may or may not be considered dedicated collections. Examples include revenue or
inflows derived from
a. concession arrangements;
b. grants for a specific project such as electric transmission lines, communication
sites, roads, trails, fiber optic lines, canals, air rights, flumes, pipelines, reservoirs
and dams;
c. land sales or land exchanges;
d. leases;
e. permits for public use such as commercial filming and photography, advertising
displays, agriculture, recreation residences and camping, recreation facilities,
temporary use permits for construction equipment storage and assembly yards,
well pumps, and other such uses;
f. forest product sales such as timber, or sales arising from national forests and
grasslands; and/or
g. public-private partnerships.
36C. Conservation and preservation land sub-category
includes land or land rights that are
predominantly used for conservation or preservation purposes. Conservation and
preservation, although closely linked, are distinct terms. Each term involves a certain type
or degree of protection. Specifically, conservation is generally associated with the
protection and proper use of natural resources, whereas preservation is associated with the
protection of buildings, objects, and landscapes from use. Examples of land conserved or
preserved for significant natural, historic, scenic, cultural, and recreational resources
include the following:
National parks
Geological resource sites
Wildlife and plant life refuges
Archeological resource sites
Local Native American or ethnic cultural sites
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36D. Operational land sub-category includes land or land rights predominantly used for general
or administrative purposes. For example, the following functions performed by entities
would be included in this sub-category:
a. Military
functions include preparing for the effective pursuit of war and military
operations short of war; conducting combat, peacekeeping, and humanitarian
military operations; and supporting civilian authorities during civil emergencies.
b. Scientific
functions include conducting and managing research, experimentation,
exploration, and operations (including the development of commercial capabilities).
Broad scientific fields of study generally include (1) physical sciences (physics,
astronomy, chemistry, geology, metallurgy), (2) biological sciences (zoology,
botany, genetics, paleontology, molecular biology, physiology), and (3) social
sciences (psychology, sociology, anthropology, economics).
c. Nuclear
functions include managing or regulating the use of nuclear energy, power
plants, radioactive materials, radioactive material shipments, nuclear storage, and
nuclear reactor decommissioning.
d. Other related
functions include those that are administrative or other mission
related in nature. For example, land used for readiness and training, office building
locations, storage, or vacant properties fall under this category.
Recognition and Measurement
37. The cost of acquisition of stewardship land should be recognized on the statement of net
cost for the period in which the cost is incurred. The cost should include all costs to prepare
stewardship land for its intended use (e.g., razing a building). In some cases, land may be
acquired along with existing structures. The following treatments should apply:
a. if the structure would be deemed a heritage asset and is significant in and of itself, the
entity should use its judgment as to whether the acquisition cost should be treated as the
cost of stewardship land, heritage asset, or both;
b. if the structure is to be used in operations (for example, as general PP&E) but 1) the value
of the structure is insignificant, or 2) its acquisition is merely a byproduct of the acquisition of
the land, the cost in its entirety should be treated as an acquisition of stewardship land; or
c. significant structures that have an operating use (e.g., a constructed hotel or employee
housing block) should be treated as general PP&E by identifying the cost attributable to
general PP&E and segregating it from the cost of the stewardship land acquired.
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38. No amounts for stewardship land acquired through donation or devise
18
should be
recognized in the cost of stewardship land.
19
39. Transfers of stewardship land from one Federal entity to another, does not affect the net
cost of operations or net position of either entity. The transferring and recipient entities
should properly adjust for estimated acres of land information.
20
Disclosures and Required Supplementary Information
40. The following [RSI information: FY 2022-2025] [disclosures: FY2026]
21-21.1
should be
provided for stewardship land and permanent land rights:
a. A concise statement defining an entity's federal land, and explaining how
stewardship land relates to the mission of the entity.
b. A brief description of the entity's policies for stewardship land. Policies for land are
the goals and principles the entity established to guide its acquisition,
maintenance, use, and disposal of land consistent with statutory requirements,
prohibitions, and limitations governing the entity and the land.
c. Information of land use by sub-category. Stewardship land and permanent land
rights should be assigned to one of three sub-categories based on predominant
use
21.1a
and reported in estimated acres of land. The three sub-categories are
commercial use land; conservation and preservation land; and operational land.
18
A will or clause of a will disposing of property.
19
SFFAS 7, Accounting for Revenue and Other Financing Sources, par. 258-259 explains that stewardship PP&E is
“expensed if purchased, but no amount is recognized if it is received as a donation.”
20
Footnote rescinded by SFFAS 59.
21
This standard does not prescribe a specific reference or line item entitled "Stewardship Land" as it may be included
with other items for which no dollar amounts are recognized (such as heritage assets and other items that in the future
may require similar non-financial disclosure) for presentation. Instead, the standard allows entities flexibility in
determining the best presentation.
21.1
Unless otherwise noted, [RSI information: FY 2022-2025] [disclosure: FY 2026] requirements are limited to the
stewardship land category and are not required for each of the three sub-categories of conservation and preservation
land; operational land; and commercial use land.
21.1a
Predominant Use of land. Predominant use is the major or primary current use of an asset during the reporting
period and does not include incidental or infrequent uses of the asset. Moreover, predominant use can change
between reporting periods. An asset's predominant use should be consistent with the entity's authorizing legislation
but may not always be consistent with the original intent or reason why the asset was initially acquired.
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Where stewardship land and permanent land rights have more than one use, the
predominant use of the land should be used to sub-categorize the land.
21.1b
i. Acres of land. The estimated number of acres at the beginning of each
reporting period among the three sub-categories and the estimated
number of acres at the end of each reporting period for land and
permanent land rights.
d. If applicable, the amount of estimated acres of land held for disposal or exchange
and their predominant use. For purposes of this Statement, stewardship land is
considered held for disposal or exchange when the entity has satisfied the
statutory disposal authority requirements specific to the land in question.
e. Stewardship land rights information should include a general description of the
different types of rights acquired by the entity, whether such rights are permanent
or temporary, and amounts paid during the year to maintain such rights.
40A. The financial statement balance sheet should reference a note that [presents RSI
information: FY 2022-2025] [discloses: FY 2026] required at paragraph 40 (a through e)
about Stewardship land and permanent land rights but no asset dollar amount should be
shown. Existing disclosures
21.2
should continue during the transition period through fiscal
year 2025 and cease in fiscal year 2026 when superseded by the transition of the RSI
information to note disclosures. If stewardship land and general PP&E land are presented
in separate notes to the financial statements, include cross references between the notes.
41.
22,
23
Entities should include a reference to the deferred maintenance and repairs
information
24
reported in required supplementary information.
21.1b
Aggregation and assignment of land. The level of aggregation of land and permanent land rights used to determine
predominant use should be determined by the preparer considering the entity's mission, types of land use and how it
manages the assets.
21.2
For stewardship land, existing disclosures are those required by paragraph 40, titled "Disclosures and Required
Supplementary Information" that are being rescinded (40.a through 40.d.3) effective fiscal year 2026. To the extent
practical, duplication of information, such as statements explaining how stewardship land relates to the entity's mission
or its SL policies and procedures, should be avoided and should remain as basic (note disclosure) during the
transitional period.
22
Footnote deleted by SFFAS 42.
23
Footnote deleted by SFFAS 42.
24
See SFFAS 42, Deferred Maintenance and Repairs, Amending Statements of Federal Financial Accounting
Standards 6, 14, 29 and 32 for information regarding definition, measurement and required supplementary information.
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U.S. Government-wide Financial Statement Disclosures
25
42. The U.S. Government-wide financial statement should include the following information:
a. A concise statement including a general description of the federal government's
land explaining how its federal land relates to the mission of the Federal
Government.
b. [RSI information: FY 2022-2025] [A disclosure FY 2026] of the estimated acres of
land by predominant use sub-categories and estimated acres of land held for
disposal or exchange by the Federal Government.
c. A general reference to agency reports for additional information about stewardship
land, such as agency policies and estimated acres of land.
42A. The U.S. Government-wide financial statement balance sheet should reference a note that
[presents RSI: FY 2022-2025] [discloses the FY 2026] information about stewardship land
and land rights required by paragraph 42, but no asset dollar amounts should be shown.
Existing disclosures
25.1
should continue during the transition period through fiscal year 2025
and cease in fiscal year 2026 when superseded by the transition of the RSI information to
note disclosures. If stewardship land and general PP&E land are presented in separate
notes to the financial statements, include cross references between the notes.
Effective Date
43. These standards are effective for reporting periods beginning after September 30, 2005 with
the exception of the specific paragraphs listed below. These exceptions provide for a phase-
in of disclosure requirements being reported as basic information such that these standards
will be fully implemented for reporting periods beginning after September 30, 2008.
a. Section c and section d1 in par. 25 and 40 are effective for reporting periods beginning
after September 30, 2007;
25
SFFAS 24, Selected Standards for the Consolidated Financial Report of the United States Government, clarified that
all existing and future standards apply to all Federal entities, including the U.S. Governmentwide Financial Statement,
unless a standard specifically provides otherwise.
25.1
Existing disclosures at paragraph 42 are those which are in effect for reporting entities prior to the amendments
contained at paragraphs 42 and 42A. To the extent practical, duplication of information, such as statements explaining
how stewardship land relates to the entity's mission or its SL policies and procedures, should be avoided and should
remain as basic (note disclosure) during the transitional period.
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b. Section d2 and section d3 in par. 25 and 40 are effective for reporting periods beginning
after September 30, 2008; and
c. Information that is provided an exception (described in par. a. and b. above) to being
reported as basic information during the phase-in period is still required, but should be
reported as RSI until the exceptions expire.
44. Full implementation of the standards is effective for reporting periods beginning after
September 30, 2008. Earlier implementation is encouraged.
The provisions of this Statement need not be applied to information if the effect of applying the
provision(s) is immaterial. Refer to Statement of Federal Financial Accounting Concepts 1,
Objectives of Federal Financial Reporting, chapter 7, titled Materiality, for a detailed discussion
of the materiality concepts.
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Appendix A: Basis for Conclusions
This appendix discusses factors considered significant by Board members in reaching the
conclusions in this Statement. It includes the reasons for accepting certain approaches and
rejecting others. Individual members gave greater weight to some factors than to others. The
standards enunciated in this statement---not the material in this appendix---should govern the
accounting for specific transactions, events or conditions.
This Statement may be affected by later Statements. The FASAB Handbook is updated annually
and includes a status section directing the reader to any subsequent Statements that amend this
Statement. Within the text of the Statements, the authoritative sections are updated for changes.
However, this appendix will not be updated to reflect future changes. The reader can review the
basis for conclusions of the amending Statement for the rationale for each amendment.
Introduction
45. In SFFAS 8, Supplementary Stewardship Reporting, the Board described stewardship
information and required the reporting of that information. When the Board established the
RSSI category, it believed that the new category was needed to highlight the unique nature
of the reported items, to accommodate non-financial data, and to allow for reporting
experimental information, such as condition. The Board believed that as agencies gained
experience in reporting stewardship information that the reporting would evolve to a level
where there was consistency within categories and at the government-wide consolidated
reporting level. The Board has found that this evolution is, in fact, happening.
46. Consequently, the Board also has considered entities’ improved accounting and reporting
methods in deciding how to categorize the stewardship elements. The Board has found that,
in many cases, entities have adopted the stewardship standards with a sense of responsible
creativity. There are many instances where entities have developed imaginative,
informative, and meaningful displays of stewardship information. The Board commends the
efforts of these entities and supports their continued efforts to report on the Nation’s
stewardship resources and responsibilities in a responsible and informative manner.
47. The Board believes that avoiding the use of the RSSI category will eliminate some potential
confusion and ambiguity. In particular, it should clarify the Board’s expectation that
significant information essential to fair presentation will be subject to audit.
48. The Board eliminated the use of RSSI to report information about weapons systems when it
issued SFFAS 23, Eliminating the Category “National Defense Property, Plant, and
Equipment.” Additionally, SFFAS 25, Reclassification of Stewardship Responsibilities and
Eliminating the Current Services Assessment, eliminated the use of RSSI for reporting
stewardship responsibilities. Classification of other items of information currently
designated RSSI (stewardship investments) may be dealt with in one or more future
standards.
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49. This standard eliminates the use of RSSI for reporting Stewardship PP&E. Stewardship
PP&E consists of items whose physical properties resemble those of general PP&E
traditionally capitalized in basic financial statements. However, the nature of Federal
physical assets classified as stewardship PP&E (e.g., museum collections, monuments,
assets acquired in the formation of the nation, etc.) differ from general PP&E. Stewardship
PP&E includes heritage assets (e.g., Federal monuments and memorials and historically or
culturally significant property) and stewardship land (i.e., land not acquired for or in
connection with general property, plant, and equipment).
26
Amendments to Standards
50. This standard amends several existing standards. The amendments rescind certain
standards or parts of certain standards due to the classification change, as well as serves as
a means to incorporate all standards specific to heritage assets and stewardship land into
one standard.
51. This standard amends SFFAS 8 by rescinding chapters 2 and 4 of that standard. This
change eliminates the use of the RSSI category to report information about heritage assets
and stewardship land. This standard also incorporates the revised multi-use heritage asset
standards of SFFAS 16, Amendments to Accounting for Property, Plant, and Equipment:
Measurement and Reporting for Multi-use Heritage Assets.
27
Accordingly, SFFAS 16 is
rescinded in its entirety. Additionally, par. 57 through 76 of SFFAS 6, Accounting for
Property, Plant and Equipment also is rescinded because they relate to heritage assets and
stewardship land.
52. SFFAS 14, Amendments to Deferred Maintenance Reporting, also amended certain
paragraphs within Chapters 2 and 4 of SFFAS 8 that related to deferred maintenance and
condition reporting. This standard also incorporates those revisions. Accordingly, the
portion of SFFAS 14 entitled ‘Amendments to SFFAS 8’ (SFFAS 14 par. 10 and 11) is
rescinded.
28
53. As a result, this standard incorporates all standards for heritage assets and stewardship
land into one document. The Board believes by fully incorporating all requirements for
heritage assets (including multi-use heritage assets) and stewardship land, readers will
26
SFFAS 8, par. 11
27
SFFAS 16 has been incorporated into the current standard for ease in understanding because SFFAS 16 amended
Chapter 2 Heritage Assets of SFFAS 8 and portions of SFFAS 6.
28
SFFAS 14 did amend the status of deferred maintenance by classifying it as RSI, however, SFFAS 6, Accounting for
Property, Plant and Equipment, provides for the information to be reported. See SFFAS 6, Chapter 3, Deferred
Maintenance (par. 77-84) for information regarding definition, measurement and disclosures specific to deferred
maintenance.
SFFAS 29
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better understand all existing reporting requirements. However, the main issues deliberated
by the Board were the reclassification and presentation of heritage assets and stewardship
land information. The Board has not reconsidered the definition, recognition and
measurement provisions of the current standards at this time. These provisions have been
brought forward from previous standards that were based on prior Boards’ conclusions. In
the future, the Board may reconsider the recognition and measurement issues for heritage
assets and stewardship land.
Basic vs. RSI
54. The Board believes that information on heritage assets and stewardship land (except for
condition) should be basic information for the following reasons:
a. Information on these assets is essential to fair presentation and may be crucial to
understanding the entirety of an entity’s financial condition.
b. Accountability for heritage assets and stewardship land requires more audit scrutiny than
would be afforded if they were considered RSI.
29
c. This classification is consistent with existing standards issued by the Governmental
Accounting Standards Board (GASB) that is specific to reporting on art and historical
treasures; and the Financial Accounting Standards Board (FASB) that is specific to
collections, and other works of art and historical treasures. There is also existing audit
guidance available in this area.
30
55. It should be noted that during Board discussions and deliberations related to SFFAS 25,
Reclassification of Stewardship Responsibilities and Eliminating the Current Services
Assessment, and the reclassification of the stewardship responsibilities, the Board
developed a detailed list of practical and conceptual factors for consideration in determining
RSI versus basic information classification. This structure was also considered in the
decisions relating to the appropriate classification of heritage assets and stewardship land
information and will be invoked in any future classification decisions by the Board.
31
29
See SFFAS 8, par. 114 which details the fact the Board believed “that certain stewardship information, should
receive more audit scrutiny than it would if it were RSI…”
30
For additional information on these existing standards and guidance see Statement of Financial Accounting
Standards 116, Accounting for Contributions Received and Contributions Made, GASB 34 par. 27-29 (Reporting Works
of Art and Historical Treasures), and AICPA Audit and Accounting Guide, Not-for-Profit Organizations.
31
See SFFAS 25, Appendix A paragraphs 34-50 for detail on the factors. To help readers understand the Board’s
deliberations, those paragraphs provide more details about some practical and conceptual factors that affected the
Board’s decision whether to designate an item as RSI or as an integral part of the basic financial statements.
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56. Specifically, the Board agreed that heritage assets and stewardship land information was
essential and relevant to fair presentation. Additionally, the Board believed that it was
important that this be clearly communicated to the readers of the financial statements and
auditor reports. The Board also noted the importance and relevance of the information in
light of the Objectives of Federal Financial Reporting.
32
57. Condition reporting for heritage assets and stewardship land should be reported as required
supplementary information because this information is experimental in nature and there is
inconsistency in the manner of assessing and reporting this information.
U.S. Government-wide Financial Statement
58. In determining the required disclosures for the U.S. Government-wide Financial Statement,
the Board considered SFFAC 4, Intended Audience and Qualitative Characteristics for the
Consolidated Financial Report of the United States Government, which designated the
intended or primary audience of the U.S. Government-wide Financial Statement and
qualitative characteristics for the U.S. Government-wide Financial Statement that would be
most useful for that audience.
33
59. Par. 6 of SFFAC 4 explains that the U.S. Government-wide Financial Statement “is a
general purpose report that is aggregated from agency reports and tells users where to find
information in other formats, both aggregated and disaggregated, such as individual agency
reports, agency websites, and the President’s Budget.”
60. The Board considered the nature and the variety of the data that would be aggregated from
the various entities in preparing the heritage assets and stewardship land disclosures for the
U.S. Government-wide Financial Statement. The Board determined that the standards for
the U.S. Government-wide Financial Statement should provide for a general discussion and
direct users to the applicable entities’ financial statements for more detailed information on
heritage assets and stewardship land.
32
See Stewardship (Objective 3) as described in SFFAC 1, Objectives of Federal Financial Reporting.
33
See SFFAC 4, Intended Audience and Qualitative Characteristics for the Consolidated Financial Report of the United
States Government par. 5
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Exposure Draft
61. FASAB published the exposure draft (ED) Heritage Assets and Stewardship Land:
Reclassification from Required Supplementary Stewardship Information on August 20,
2003. Upon release of the ED, notices and/or press releases were provided to: the Federal
Register; the FASAB News, the Journal of Accountancy, AGA Today, the CPA Journal,
Government Executive, the CPA Letter, Government Accounting and Auditing Update, and
JFMIP News; the CFO Council, the Presidents Council on Integrity and Efficiency, the
Financial Statement Audit Network, the Federal Financial Managers Council; and
committees of professional associations generally commenting on exposure drafts in the
past.
62. Twelve letters were received from the following sources:
63. A public hearing was held on March 4, 2004. Individuals from the Library of Congress, U.S.
Department of Agriculture, Department of Interior (including representatives from the CFO,
OIG and IPA currently performing the DOI audit), and a representative from the Institute for
Truth in Accounting testified at the public hearing. The participants reiterated issues
included in the comment letters to the ED.
Responses to the ED
64. A majority of the respondents did not agree with heritage assets and stewardship land
information being reported as basic. Key issues raised by respondents included the
following:
a. A need for more specific guidance on categorization and unitization for reporting
heritage assets and stewardship land information;
b. The audit implications of the standard, including the additional audit costs by classifying
the information as basic; and
c. Less useful information being presented by agencies with the reclassification.
FEDERAL
(internal)
NONFEDERAL
(external)
Users, academics, others 1 3
Auditors 1 1
Preparers and financial managers 6
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65. Most respondents that did not agree with heritage assets and stewardship land information
being reported as basic, recommended that it be classified as RSI (or remain as RSSI).
66. Most respondents agreed with the Board’s new disclosure requirements and did not foresee
any problems with the new disclosure requirements
67. Most respondents did not agree with the proposed effective date for periods beginning after
September 30, 2004 in the ED. Key reasons cited for the delay of the effective date
included the need for additional time to address implementation issues and time for
including funding in their budgets to cover the additional costs for implementation and audit.
Board Consideration of Comments
68. Considering that the majority of respondents did not agree with the ED, the Board directed
staff to research various issues that would assist the Board in addressing the comments
raised by respondents. For example, the Board considered the current FASB and GASB
standards in this area. The Board also considered results of a review of private museum
reporting practices.
69. The Board also considered several recent government-wide initiatives that promote
accountability and stewardship over real property assets and heritage assets such as the
Federal Real Property Asset Management Initiative, Executive Order 13327 Federal Real
Property Asset Management, and Executive Order 13287 Preserve America. The Board
believes these initiatives provide further support for the decision to classify the heritage
assets and stewardship land as basic information and the importance of accountability for
these types of assets.
70. The Board also considered the issue of unitization and categorization further by reviewing
draft guidance prepared by the Heritage Assets Categorization Project Team and the
Accounting and Auditing Policy Committee (AAPC) Stewardship Guidance Workgroup. The
Board believes that the draft products from these workgroups are excellent starting points
for developing comprehensive guidance on many of the issues raised by respondents.
71. In response to the audit concerns, FASAB held a roundtable meeting with representatives
from the Office of Inspector General (OIG) and CPA firms responsible for financial statement
audits to solicit their views on specific issues raised by respondents as well as potential
audit costs involved with implementing the standard.
72. As a result of the comments received and testimony provided at the public hearing, as well
as the above actions, the Board did make certain revisions, which are detailed in the
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following paragraphs. Additionally, reasons for not making revisions on specific issues are
detailed below.
Importance to Mission
73. The ED contained the new disclosure that required a statement explaining how heritage
assets and stewardship land are “important to the overall mission of the entity.” A
respondent explained that agencies may have significant stewardship assets as a result of
their compliance with cultural resource protection laws and regulations or because
Congress has determined that certain classes of assets to be nationally significant,
regardless of the agency mission. The respondent believed that showing the link between
the agency mission and the assets may result in less disclosure by agencies that lack a
direct link to their mission.
74. The Board understands that some agencies may have heritage assets because of the facts
described by the respondent and it is possible that the assets may not be important to the
overall mission of the agency. However, the Board considered the new requirement to be
explanatory in nature by offering more information about the assets. The Board did not
envision the importance to the mission to be considered in determining which heritage
assets and stewardship land should be included.
75. The Board revised the language of the new requirement to read “A concise statement
explaining how they relate to the mission of the entity.” The Board believes with this
language, the requirement is flexible enough that if the assets are not related to the mission
of the entity, the entity may state that and provide additional explanation, if they so choose.
Limiting Information Presented
76. Several respondents commented that agencies would present less information in their
annual reports because the heritage assets information and stewardship land information
would be subject to audit since it is classified as basic information. The classification of
heritage assets and stewardship land information as basic should not limit the information
entities choose to present or prevent the continuation of informative and meaningful
displays of information.
77. This standard does not eliminate any information that was previously required for heritage
assets and stewardship land. In drafting the standard, the Board envisioned the required
disclosures to be presented in a concise format similar to the format that most entities
present for general property, plant and equipment.
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78. The Board notes that preparers continue to have the option of voluntarily presenting
information beyond the minimum reporting requirements as other accompanying
information.
Categorization and Unitization
79. The standard does not define asset categories or physical units for reporting. The Board
recognizes that there may be difficulties for agencies in determining the appropriate level of
aggregation for reporting categories of heritage assets. However, the Board believes that
the agencies are in the best position to determine the most meaningful level of presentation.
The Board believes that ultimately the presentation depends upon the specifics of the
entity—its mission, the types of heritage assets, how it manages, and materiality
considerations. It would be difficult for the standard to define such specific reporting
requirements, as they may be unique to each entity.
80. The Board also has avoided detailed illustrations and limited specific examples in the
standard because preparers and auditors may attempt to strictly adhere to the illustrations.
81. The standard emphasizes reporting on asset categories, rather than individual assets.
Based on comments to the ED, it appeared that this may not have been clear to the readers.
Therefore, additional language was added to the final standard to clarify that the appropriate
level of categorization of stewardship assets and the associated physical units should be
determined by the preparer based on the entity’s mission, types of use, and how it manages
the assets.
82. Entities should designate asset reporting categories that allow inclusion and aggregation of
their heritage assets and stewardship land. Entities should determine the appropriate level
of detail for their categorization. It is helpful if entities designate asset categories that are
meaningful and reflect how the entity views the assets for management purposes. It would
also be helpful for entities to document the reasoning for the categorization.
83. The Board recognizes that the information that is appropriate for reporting heritage assets
and stewardship land can vary from one entity to another. The amount and level of detail of
the information presented depends, in part, on the mission of the entity and the materiality of
the assets in question. For example, categories reported by an agency that has a
stewardship mission, might be more disaggregated than is appropriate for one that does
not.
84. Defining physical units as individual items to be counted is neither required nor prohibited.
Particularly for collection-type heritage assets, it may be more appropriate to define the
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SFFAS 29
physical unit as a collection, or a group of assets located at one facility, and then count the
number of collections or facilities. The level of detail may differ by entity.
85. It is the intent of the Board to provide entities with considerable latitude and flexibility in
designating categories, determining a meaningful level of aggregation for reporting, and
selecting physical units aligned with those categories. For example, should a library report
that it has a collection of papers or that it has 10,000 pieces of paper in that collection?
Further, should a museum report that has 10 dinosaur skeletons or 10,000 dinosaur bones,
or a single collection of skeletons in one facility? Ultimately, the answer is influenced by
how the entity manages as well as materiality considerations. Agencies may be required to
count the number of individual items for control purposes. But due to materiality
considerations, entities may choose to report a higher level of aggregation such as the
number of collections or facilities in which individual items are located. Although individual
item counts may not be necessary to support the reporting requirements in the standard,
this does not mean that item counts for management control and safeguarding purposes are
not necessary to fulfill mandates required by other public laws and regulations.
Supporting Documentation
86. The Board has recognized in previous standards that historical records for items acquired
long ago may not have been retained.
34
Based on responses to the ED, testimony provided
at the public hearing, and discussions with the auditors at the roundtable meeting, the Board
believes this may be an issue in implementing this standard.
87. The Board understands that with the heritage assets and stewardship land information
being classified as basic, auditors may require certain supporting documentation to fulfill
audit assertions. There may be instances where the historical documents are not available
for items acquired many years ago, prior to the effective date of this standard, in an
environment in which the historical records were not required to be retained and may
therefore be inadequate.
88. Therefore, the Board encourages preparers, program offices, and auditors to develop other
reasonable approaches and methods for satisfying the specific audit assertions that would
rely on historical documents as evidence and support. In addition, the Board plans to
34
SFFAS 23 Eliminating the Category National Defense PP&E, par. 11 provided implementation guidance as follows:
“This standard recognizes that determining initial historical cost may not be practical for items acquired many years
prior to the effective date of this standard in an environment in which the historical records were not required to be
retained and may therefore be inadequate.”
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suggest that this issue be addressed further in the forthcoming AAPC Guidance (discussed
below).
Additional Guidance
89. The Board notes that there has been work by certain government-wide task forces (such as
the AAPC Stewardship Guidance Work Group and the Heritage Assets Categorization
Team) to address issues identified such as standardized categories, definitions of units of
measurements, and other areas where prescriptive guidance has been requested. The task
forces contained representatives from pertinent agencies and experts in the field, which
most likely provided for a comprehensive assessment.
90. Considering the extensive research performed by the task forces, their draft proposals or
guides which address areas such as categories and subcategories and related physical
units should be a good starting point for additional guidance that could be included in a
Technical Release from the AAPC.
91. The Board will request that the AAPC revitalize the efforts of the Stewardship Guidance
Work Group and work towards finalization of their draft guidance, which may ultimately be
published as a Technical Release. The guidance will be expanded where necessary to
cover the issues identified by respondents in the comment letters. For example, the Board
will suggest that the AAPC review case studies where supporting documentation may not
be available and determine other reasonable approaches, methods, and best practices for
satisfying specific assertions that would rely on historical documents as evidence and
support.
92. The Board will suggest that the AAPC also consider the work done by the Heritage Assets
Categorization Team. FASAB staff will work closely with the task force with the goal of
finalizing the guide within one year of the issuance of this standard.
Effective Date/Phased-In Implementation
93. Most respondents to the ED and participants at the public hearing did not agree with the
proposed effective date in the ED for periods beginning after September 30, 2004. Key
reasons cited for the delay of the effective date were the need for additional time to address
issues noted in their arguments against classifying the information as basic and time for
including funding in their budgets for the additional work and audit costs to be incurred.
94. The Board believed the reasons provided for the delay of the effective date were valid and
justified some delay. Therefore, the Board believed a phased implementation would provide
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time for entities to address some of the issues identified and for consideration of the
strained resources facing most agencies.
95. The Board also believed that the effective date for certain disclosures to be classified as
basic should be delayed to allow time for the issuance of the additional guidance by the
AAPC. Therefore, the standard was revised to allow for a phase-in of required reporting
disclosures as basic.
96. The standards are effective for reporting periods beginning after September 30, 2005, with
the exception of the section c (category descriptions) and section d1 (physical units by
major category for the end of the reporting period) in par. 25 and 40 that are effective for
reporting periods beginning after September 30, 2007; and section d2 (physical units by
major category that were acquired and withdrawn during the reporting period) and section
d3 (major methods of acquisition and withdrawal during the reporting period) in par. 25 and
40 that are effective for reporting periods beginning after September 30, 2008.
97. These exceptions provide for a phase-in of disclosure requirements being reported as basic
information such that the standard will be fully implemented for reporting periods beginning
after September 30, 2008. Information that is provided an exception (see par. above) to
being reported as basic information during the phase-in period is still required, but should be
reported as RSI until the exceptions expire. It may be appropriate for entities to include a
reference to the information reported as RSI during the phase-in period.
98. The phased-in implementation offers additional time for agencies to determine the proper
level of aggregation for major categories, as well as determining the appropriate physical
unit of measure and documenting their reasoning for such. This additional time will also
allow for the AAPC to issue its guidance in time for consideration before implementation. It
is anticipated that the AAPC will finalize the guide prior to the implementation of the required
reporting by major categories.
Materiality
99. In the ED, the disclosure requirements language read “Entities with significant heritage
assets/stewardship land should reference a note…” The Board used the term “significant”
to emphasize that some entities may not be subject to the disclosure requirements due to
certain entities having only immaterial amounts of heritage assets and stewardship land
covered by this standard.
100. Although most respondents to the ED agreed that the preparer should have flexibility in
determining appropriate categories for aggregation and that the preparer should be allowed
to exercise professional judgment in determining which assets are significant, there was
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SFFAS 29
some concern raised by respondents that these judgments may be difficult to make. Certain
respondents noted that “significant” is difficult to apply in the case of heritage assets and
stewardship land because there are no financial dollar amounts required to be reported.
101. The term significant” was removed from the language establishing disclosure requirements
in the final standard because the Board has stated within this standard “The provisions of
this Statement need not be applied to immaterial items.” Therefore, entities may omit
heritage asset and stewardship land information if they are immaterial.
102. In SFFAS 3, Accounting for Inventory and Related Property, the introduction included a
discussion on "materiality".
35
It explained that materiality has not been strictly defined in the
accounting community; rather, it has been a matter of judgment on the part of preparers of
financial statements and the auditors who attest to them. It further explained that the
determination of whether an item is immaterial requires the exercise of considerable
judgment, based on consideration of specific facts and circumstances.
103. In its discussion in SFFAS 3, the Board relied on the FASB’s concept as modified by certain
concepts expressed in governmental auditing standards.
36
Par. 9 of SFFAS 3 discussed
FASB's Statement of Financial Accounting Concepts No. 2, "Qualitative Characteristics of
Accounting Information," that provides for materiality as the magnitude of an omission or
misstatement of accounting information that, in the light of surrounding circumstances,
makes it probable that the judgment of a reasonable person relying on the information would
have been changed or influenced by the omission or misstatement.
104. Par. 9 of SFFAS 3 also explains that this concept includes both qualitative and quantitative
considerations. An item that is not considered material from a quantitative standpoint may
be considered qualitatively material if it would influence or change the judgment of the
financial statement user. The Board believes that preparers should consider both
quantitative and qualitative characteristics when applying materiality to this standard.
Board Approval
105. This statement was approved for issuance by all members of the Board.
35
See SFFAS 3, Accounting for Inventory and Related Property, par. 7-15.
36
Par. 12 of SFFAS 3 explains that the Government Auditing Standards provide "In government audits the materiality
level and/or threshold of acceptable risk may be lower than in similar-type audits in the private-sector because of the
public accountability of the entity, the various legal and regulatory requirements, and the visibility and sensitivity of
government programs, activities, and functions."