Despite whatever back-office work may still remain unfinished, the Financial Accounting Standards Board has promised its guidance requiring new disclosures around off-balance-sheet activity will be finalized by Dec. 15 so that it can be effective at the same time it is issued.

FASB is putting the finishing touches on FASB Staff Position (FSP) FAS 140-4 and FIN 46(R)-8, Disclosures About Transfers of Financial Assets and Interests in Variable Interest Entities to require better disclosures around off-balance-sheet securitized transactions with the current reporting cycle. It’s something of a stop-gap measure while FASB also works to amend Financial Accounting Statement No. 140, Accounting for Transfers and Servicing of Financial Assets and Extinguishments of Liabilities, and Financial Interpretation No. 46R, Consolidation of Variable Interest Entities. The short-term guidance will require more disclosures about transfers of financial assets and variable interests in qualifying special purpose entities as well as involvement with variable interest entities.

At its meeting just before the Thanksgiving break, FASB was still wrestling with some fine points in the proposed guidance. The board determined that it would require the disclosure requirements of the guidance to apply not only to annual periods, but to quarterly reporting periods as well. The board also determined that entities that either sponsor a variable interest in a QSPE or service a significant variable interest in a QSPE should disclose their maximum exposure to any loss that might result from their involvement. The board has summarized all of its decisions to date in a project summary available on its Website.