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Question 1 of 10
1. Question
Excerpt from a regulator information request: In work related to Closing Procedures as part of sanctions screening at a wealth manager, it was noted that the internal audit team found discrepancies in the valuation of Right-of-Use (ROU) assets during the transition to ASC 842. Specifically, for a new 5-year lease of specialized financial terminals, the closing team struggled to identify which costs should be capitalized into the asset base versus expensed immediately. Under ASC 842 and IFRS 16, which of the following correctly identifies the components required for the initial measurement of the Right-of-Use (ROU) asset?
Correct
Correct: Under both ASC 842 and IFRS 16, the initial measurement of the ROU asset is derived from the lease liability. It specifically includes the initial lease liability amount, any payments made to the lessor before or at commencement (prepaid rent), and initial direct costs (incremental costs that would not have been incurred if the lease had not been obtained), while subtracting any lease incentives received from the lessor.
Incorrect: Excluding initial direct costs or prepayments is incorrect because these are required components of the ROU asset under the new standards. Using the fair value of the underlying asset is not the standard lessee ROU measurement, which is based on the present value of lease payments. Using undiscounted payments ignores the fundamental requirement to present the lease liability at present value, which forms the basis of the ROU asset.
Takeaway: The ROU asset is a capitalized value comprising the lease liability, prepayments, and direct costs, net of incentives.
Incorrect
Correct: Under both ASC 842 and IFRS 16, the initial measurement of the ROU asset is derived from the lease liability. It specifically includes the initial lease liability amount, any payments made to the lessor before or at commencement (prepaid rent), and initial direct costs (incremental costs that would not have been incurred if the lease had not been obtained), while subtracting any lease incentives received from the lessor.
Incorrect: Excluding initial direct costs or prepayments is incorrect because these are required components of the ROU asset under the new standards. Using the fair value of the underlying asset is not the standard lessee ROU measurement, which is based on the present value of lease payments. Using undiscounted payments ignores the fundamental requirement to present the lease liability at present value, which forms the basis of the ROU asset.
Takeaway: The ROU asset is a capitalized value comprising the lease liability, prepayments, and direct costs, net of incentives.
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Question 2 of 10
2. Question
The operations team at a wealth manager has encountered an exception involving Other Relevant Regulations during periodic review. They report that a portfolio of IT server leases, which were initially classified as short-term leases (12 months or less) and kept off the balance sheet, have been modified to extend the term by an additional 9 months. This modification brings the total lease term to 21 months. The internal audit team must determine the appropriate accounting treatment under ASC 842 for these modified contracts. Which of the following actions is required regarding the recognition of these leases?
Correct
Correct: Under ASC 842, when a lease modification occurs that results in the lease no longer qualifying for the short-term lease exemption (i.e., the lease term becomes greater than 12 months), the lessee must recognize a right-of-use (ROU) asset and a lease liability. This recognition is performed as of the effective date of the modification, using the remaining lease payments and the appropriate discount rate at that time.
Incorrect: Option b is incorrect because the short-term exemption is based on the total lease term of the modified contract, not just the remaining term at the time of the amendment. Option c is incorrect because lease modifications are generally accounted for prospectively from the modification date rather than through retrospective restatement of prior periods. Option d is incorrect because a modification does not automatically dictate a finance lease classification; the lease must still be evaluated against the five classification criteria (such as transfer of ownership or bargain purchase options) to determine if it is operating or finance.
Takeaway: A lease modification that extends the total term beyond 12 months requires the lessee to terminate the short-term exemption and recognize the lease on the balance sheet prospectively.
Incorrect
Correct: Under ASC 842, when a lease modification occurs that results in the lease no longer qualifying for the short-term lease exemption (i.e., the lease term becomes greater than 12 months), the lessee must recognize a right-of-use (ROU) asset and a lease liability. This recognition is performed as of the effective date of the modification, using the remaining lease payments and the appropriate discount rate at that time.
Incorrect: Option b is incorrect because the short-term exemption is based on the total lease term of the modified contract, not just the remaining term at the time of the amendment. Option c is incorrect because lease modifications are generally accounted for prospectively from the modification date rather than through retrospective restatement of prior periods. Option d is incorrect because a modification does not automatically dictate a finance lease classification; the lease must still be evaluated against the five classification criteria (such as transfer of ownership or bargain purchase options) to determine if it is operating or finance.
Takeaway: A lease modification that extends the total term beyond 12 months requires the lessee to terminate the short-term exemption and recognize the lease on the balance sheet prospectively.
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Question 3 of 10
3. Question
The quality assurance team at a wealth manager identified a finding related to Risk Appetite and Tolerance as part of incident response. The assessment reveals that the organization’s internal threshold for ‘low-value’ lease exemptions under IFRS 16 was set at $15,000 per asset to reduce the administrative burden of tracking Right-of-Use (ROU) assets. However, a recent audit of the IT equipment leasing portfolio indicates that the aggregate value of these unrecorded leases now represents 8% of total liabilities, which exceeds the 5% variance limit defined in the corporate risk tolerance framework. The Chief Financial Officer must now address the misalignment between operational accounting policy and the board-approved risk appetite.
Correct
Correct: Under IFRS 16, while an exemption exists for low-value assets, the application of this exemption must not result in a material misstatement of the financial statements. If the aggregate value of excluded leases exceeds the organization’s established risk tolerance (in this case, 5% of liabilities), the threshold must be adjusted downward. This ensures that the financial reporting remains aligned with the board’s risk appetite for accuracy and compliance.
Incorrect: Increasing disclosures does not rectify the breach of risk tolerance regarding the recognition of liabilities on the balance sheet. Amending the risk tolerance framework simply to accommodate a policy breach undermines the governance structure and does not address the underlying reporting risk. Transferring responsibility to a non-accounting department like IT procurement is inappropriate as it removes necessary financial oversight and does not solve the compliance issue regarding lease recognition standards.
Takeaway: Lease accounting thresholds for low-value assets must be calibrated so that the aggregate effect of excluded leases does not exceed the organization’s defined risk tolerance for financial reporting errors.
Incorrect
Correct: Under IFRS 16, while an exemption exists for low-value assets, the application of this exemption must not result in a material misstatement of the financial statements. If the aggregate value of excluded leases exceeds the organization’s established risk tolerance (in this case, 5% of liabilities), the threshold must be adjusted downward. This ensures that the financial reporting remains aligned with the board’s risk appetite for accuracy and compliance.
Incorrect: Increasing disclosures does not rectify the breach of risk tolerance regarding the recognition of liabilities on the balance sheet. Amending the risk tolerance framework simply to accommodate a policy breach undermines the governance structure and does not address the underlying reporting risk. Transferring responsibility to a non-accounting department like IT procurement is inappropriate as it removes necessary financial oversight and does not solve the compliance issue regarding lease recognition standards.
Takeaway: Lease accounting thresholds for low-value assets must be calibrated so that the aggregate effect of excluded leases does not exceed the organization’s defined risk tolerance for financial reporting errors.
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Question 4 of 10
4. Question
When addressing a deficiency in Impact of Tenant Bankruptcy on Lease, what should be done first? A lessor’s internal audit team discovers that the credit department failed to update the risk rating for a major tenant that recently filed for Chapter 11 bankruptcy protection. To ensure compliance with ASC 842 regarding lease accounting and financial reporting, the lessor must determine the appropriate accounting treatment for the existing operating lease.
Correct
Correct: Under ASC 842, if a lessor determines that the collectibility of lease payments is not probable, the lessor must limit the lease income recognized to the lesser of the income that would be recognized on a straight-line basis or the lease payments actually received (cash basis). Therefore, the first step in addressing a deficiency related to a bankrupt tenant is to perform a collectibility assessment to determine if the accrual-based recognition remains appropriate.
Incorrect: Terminating the lease immediately is incorrect because bankruptcy law generally stays such actions and allows the debtor to assume or reject the lease. Adjusting the discount rate for an existing lease due to changes in credit risk is not permitted under ASC 842, as the rate is typically fixed at commencement unless a modification occurs. Reclassifying the lease from operating to sales-type is also prohibited because lease classification is determined at the commencement date and is not revisited solely due to changes in the lessee’s creditworthiness.
Takeaway: When a lessee’s creditworthiness deteriorates significantly, such as in bankruptcy, the lessor must evaluate collectibility to determine if lease income should be recognized on a cash basis under ASC 842.
Incorrect
Correct: Under ASC 842, if a lessor determines that the collectibility of lease payments is not probable, the lessor must limit the lease income recognized to the lesser of the income that would be recognized on a straight-line basis or the lease payments actually received (cash basis). Therefore, the first step in addressing a deficiency related to a bankrupt tenant is to perform a collectibility assessment to determine if the accrual-based recognition remains appropriate.
Incorrect: Terminating the lease immediately is incorrect because bankruptcy law generally stays such actions and allows the debtor to assume or reject the lease. Adjusting the discount rate for an existing lease due to changes in credit risk is not permitted under ASC 842, as the rate is typically fixed at commencement unless a modification occurs. Reclassifying the lease from operating to sales-type is also prohibited because lease classification is determined at the commencement date and is not revisited solely due to changes in the lessee’s creditworthiness.
Takeaway: When a lessee’s creditworthiness deteriorates significantly, such as in bankruptcy, the lessor must evaluate collectibility to determine if lease income should be recognized on a cash basis under ASC 842.
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Question 5 of 10
5. Question
A new business initiative at a fund administrator requires guidance on Securitization Process as part of client suitability. The proposal raises questions about the accounting treatment of a portfolio of equipment leases being transferred to a Special Purpose Entity (SPE). The administrator is evaluating whether the transfer qualifies as a sale under ASC 842 and ASC 860, specifically focusing on the retention of servicing rights and the impact on the Right-of-Use (ROU) assets. If the transferor maintains effective control over the leased assets through a repurchase agreement that expires in 180 days, how should the transaction be reflected on the transferor’s financial statements?
Correct
Correct: According to ASC 860 (Transfers and Servicing), a transfer of financial assets is only accounted for as a sale if the transferor surrenders control. If the transferor maintains effective control, such as through a repurchase agreement, the transaction fails the ‘true sale’ criteria. In this scenario, the transferor must continue to report the leased assets on its balance sheet and recognize the proceeds received as a secured borrowing (a financial liability).
Incorrect: Treating the transaction as a derecognition event is incorrect because the retention of control via a repurchase agreement prevents the transaction from being classified as a sale. Classifying the transaction as a lease modification is incorrect because a securitization involves the transfer of financial interests to a third party (SPE) and does not change the contractual terms between the original lessor and lessee. A sale-leaseback arrangement is a specific accounting model under ASC 842 for selling a physical asset and leasing it back, which does not apply to the securitization of existing lease receivables where control is not surrendered.
Takeaway: Securitization transactions that fail to meet ‘true sale’ criteria due to retained control must be accounted for as secured borrowings rather than asset derecognition.
Incorrect
Correct: According to ASC 860 (Transfers and Servicing), a transfer of financial assets is only accounted for as a sale if the transferor surrenders control. If the transferor maintains effective control, such as through a repurchase agreement, the transaction fails the ‘true sale’ criteria. In this scenario, the transferor must continue to report the leased assets on its balance sheet and recognize the proceeds received as a secured borrowing (a financial liability).
Incorrect: Treating the transaction as a derecognition event is incorrect because the retention of control via a repurchase agreement prevents the transaction from being classified as a sale. Classifying the transaction as a lease modification is incorrect because a securitization involves the transfer of financial interests to a third party (SPE) and does not change the contractual terms between the original lessor and lessee. A sale-leaseback arrangement is a specific accounting model under ASC 842 for selling a physical asset and leasing it back, which does not apply to the securitization of existing lease receivables where control is not surrendered.
Takeaway: Securitization transactions that fail to meet ‘true sale’ criteria due to retained control must be accounted for as secured borrowings rather than asset derecognition.
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Question 6 of 10
6. Question
The board of directors at a wealth manager has asked for a recommendation regarding Lease Defaults and Workout Strategies as part of transaction monitoring. The background paper states that the firm is currently renegotiating several high-value technology leases that have fallen into technical default due to liquidity constraints. The proposed workout involves extending the lease term by 24 months and reducing the monthly payment amount to facilitate recovery. As the internal auditor reviewing the compliance of this strategy with ASC 842, you must determine the appropriate accounting treatment for these modifications.
Correct
Correct: Under ASC 842, when a lease modification occurs that does not result in a separate contract (such as extending the term of an existing asset), the lessee is required to remeasure the lease liability. This remeasurement must use a revised discount rate (the incremental borrowing rate) as of the effective date of the modification. A corresponding adjustment is then made to the right-of-use (ROU) asset to reflect the change in the liability.
Incorrect: Accounting for a modification as a separate contract is only appropriate if the modification grants the lessee an additional right of use (e.g., additional equipment or space) at a price that is commensurate with the standalone price for that additional use. Recognizing an immediate impairment loss is incorrect because a modification to terms and payments is a remeasurement event, not necessarily an impairment event under ASC 360. Treating the extension as a contingent rental expense is prohibited under ASC 842, which requires all fixed payments over the enforceable term to be recognized as part of the lease liability.
Takeaway: Lease modifications involving term extensions and payment changes require a remeasurement of the lease liability using a current discount rate and a corresponding adjustment to the ROU asset.
Incorrect
Correct: Under ASC 842, when a lease modification occurs that does not result in a separate contract (such as extending the term of an existing asset), the lessee is required to remeasure the lease liability. This remeasurement must use a revised discount rate (the incremental borrowing rate) as of the effective date of the modification. A corresponding adjustment is then made to the right-of-use (ROU) asset to reflect the change in the liability.
Incorrect: Accounting for a modification as a separate contract is only appropriate if the modification grants the lessee an additional right of use (e.g., additional equipment or space) at a price that is commensurate with the standalone price for that additional use. Recognizing an immediate impairment loss is incorrect because a modification to terms and payments is a remeasurement event, not necessarily an impairment event under ASC 360. Treating the extension as a contingent rental expense is prohibited under ASC 842, which requires all fixed payments over the enforceable term to be recognized as part of the lease liability.
Takeaway: Lease modifications involving term extensions and payment changes require a remeasurement of the lease liability using a current discount rate and a corresponding adjustment to the ROU asset.
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Question 7 of 10
7. Question
You are the product governance lead at an investment firm. While working on Reactive Maintenance Procedures during model risk, you receive a board risk appetite review pack. The issue is that the current accounting model for a fleet of leased specialized medical equipment treats all reactive maintenance costs as part of the fixed lease payments. These maintenance events are unscheduled, triggered only by equipment failure, and billed separately by the lessor based on actual labor and parts. Under ASC 842, how should these reactive maintenance payments be recognized in the financial statements?
Correct
Correct: Under ASC 842 and IFRS 16, variable lease payments that do not depend on an index or a rate (such as those triggered by specific events like reactive maintenance or usage) are excluded from the measurement of the lease liability and the Right-of-Use (ROU) asset. These payments are recognized as an expense in the period in which the event or condition that triggers the payment occurs.
Incorrect: Capitalizing estimated costs based on historical averages is incorrect because only variable payments based on an index or rate are included in the initial measurement of the ROU asset. Including projected costs in the lease liability is incorrect as variable payments not tied to an index/rate do not meet the definition of lease payments for liability calculation. Treating maintenance as a lease modification is incorrect because a modification involves a change in the scope or consideration of a contract that was not part of the original terms, whereas reactive maintenance is a variable expense or a non-lease component.
Takeaway: Variable lease payments not tied to an index or rate, such as reactive maintenance, must be expensed as incurred rather than capitalized into the lease liability or ROU asset.
Incorrect
Correct: Under ASC 842 and IFRS 16, variable lease payments that do not depend on an index or a rate (such as those triggered by specific events like reactive maintenance or usage) are excluded from the measurement of the lease liability and the Right-of-Use (ROU) asset. These payments are recognized as an expense in the period in which the event or condition that triggers the payment occurs.
Incorrect: Capitalizing estimated costs based on historical averages is incorrect because only variable payments based on an index or rate are included in the initial measurement of the ROU asset. Including projected costs in the lease liability is incorrect as variable payments not tied to an index/rate do not meet the definition of lease payments for liability calculation. Treating maintenance as a lease modification is incorrect because a modification involves a change in the scope or consideration of a contract that was not part of the original terms, whereas reactive maintenance is a variable expense or a non-lease component.
Takeaway: Variable lease payments not tied to an index or rate, such as reactive maintenance, must be expensed as incurred rather than capitalized into the lease liability or ROU asset.
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Question 8 of 10
8. Question
Which approach is most appropriate when applying Review of Tenant Financial Statements in a real-world setting? A commercial equipment lessor is evaluating a prospective lessee’s financial health following the full implementation of ASC 842. The lessee has a significant portfolio of operating leases that were previously off-balance sheet. When analyzing the lessee’s liquidity and leverage ratios to determine credit risk, how should the lessor interpret the newly recognized Right-of-Use (ROU) assets and lease liabilities?
Correct
Correct: Under ASC 842, the recognition of lease liabilities on the balance sheet increases reported liabilities, which can negatively impact leverage ratios. However, the ROU asset is a non-monetary asset representing the right to use an underlying asset; it is not a liquid resource available to pay off debts. Therefore, a lessor must evaluate the lessee’s cash flow and debt-service coverage, acknowledging that the balance sheet now reflects long-term commitments that were previously disclosed only in footnotes.
Incorrect: Treating the ROU asset as a liquid asset is incorrect because it cannot be converted to cash to meet short-term obligations. Excluding lease liabilities from debt calculations is inappropriate for risk assessment as they represent firm legal obligations that impact a company’s financial flexibility. Assuming an improvement in debt-to-equity is generally incorrect; the addition of a new liability typically increases leverage, and any minor adjustments for initial direct costs do not fundamentally change the increased debt profile of the lessee.
Takeaway: ASC 842 requires analysts to recognize that while lease liabilities increase reported debt, the corresponding ROU assets do not improve liquidity, requiring a deeper focus on cash-flow-based coverage ratios.
Incorrect
Correct: Under ASC 842, the recognition of lease liabilities on the balance sheet increases reported liabilities, which can negatively impact leverage ratios. However, the ROU asset is a non-monetary asset representing the right to use an underlying asset; it is not a liquid resource available to pay off debts. Therefore, a lessor must evaluate the lessee’s cash flow and debt-service coverage, acknowledging that the balance sheet now reflects long-term commitments that were previously disclosed only in footnotes.
Incorrect: Treating the ROU asset as a liquid asset is incorrect because it cannot be converted to cash to meet short-term obligations. Excluding lease liabilities from debt calculations is inappropriate for risk assessment as they represent firm legal obligations that impact a company’s financial flexibility. Assuming an improvement in debt-to-equity is generally incorrect; the addition of a new liability typically increases leverage, and any minor adjustments for initial direct costs do not fundamentally change the increased debt profile of the lessee.
Takeaway: ASC 842 requires analysts to recognize that while lease liabilities increase reported debt, the corresponding ROU assets do not improve liquidity, requiring a deeper focus on cash-flow-based coverage ratios.
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Question 9 of 10
9. Question
Following an on-site examination at a mid-sized retail bank, regulators raised concerns about Features and Functionality in the context of control testing. Their preliminary finding is that the bank’s internal controls are insufficient to identify embedded leases within service contracts, potentially leading to an understatement of lease liabilities on the balance sheet. During the audit of the previous year’s IT service agreements, it was discovered that several contracts for dedicated server space were treated as service expenses rather than Right-of-Use (ROU) assets. Which of the following control activities would best mitigate the risk of misclassifying or omitting embedded leases under ASC 842?
Correct
Correct: Under ASC 842, a lease exists if a contract conveys the right to control the use of an identified asset for a period of time. Identifying embedded leases requires evaluating whether the supplier has substantive substitution rights and whether the customer directs the use of the asset. A cross-functional review ensures that the technical accounting criteria are applied to procurement activities that might otherwise be viewed strictly as service arrangements.
Incorrect: Restricting the definition to contracts with title transfer describes only one specific type of finance lease and ignores the broader definition of a lease under ASC 842. Automatically classifying all long-term service contracts as finance leases is incorrect because many may not meet the lease criteria at all, or may be operating leases. Using a high materiality threshold to exclude service contracts from the identification process violates the requirement to evaluate contracts for lease components regardless of their initial classification as services.
Takeaway: Effective lease identification controls must focus on the substantive criteria of asset identification and control rights rather than the legal form or title of the contract.
Incorrect
Correct: Under ASC 842, a lease exists if a contract conveys the right to control the use of an identified asset for a period of time. Identifying embedded leases requires evaluating whether the supplier has substantive substitution rights and whether the customer directs the use of the asset. A cross-functional review ensures that the technical accounting criteria are applied to procurement activities that might otherwise be viewed strictly as service arrangements.
Incorrect: Restricting the definition to contracts with title transfer describes only one specific type of finance lease and ignores the broader definition of a lease under ASC 842. Automatically classifying all long-term service contracts as finance leases is incorrect because many may not meet the lease criteria at all, or may be operating leases. Using a high materiality threshold to exclude service contracts from the identification process violates the requirement to evaluate contracts for lease components regardless of their initial classification as services.
Takeaway: Effective lease identification controls must focus on the substantive criteria of asset identification and control rights rather than the legal form or title of the contract.
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Question 10 of 10
10. Question
As the MLRO at an investment firm, you are reviewing Treatment of Leases in Bankruptcy during third-party risk when a customer complaint arrives on your desk. It reveals that a critical logistics partner has filed for Chapter 11 bankruptcy and is attempting to maintain its fleet of specialized transport vehicles without addressing six months of unpaid lease invoices. The firm’s legal counsel is evaluating the partner’s rights under Section 365 of the Bankruptcy Code regarding these unexpired leases. If the logistics partner intends to keep the equipment and continue the lease relationship, which action is legally required of them?
Correct
Correct: Under Section 365 of the Bankruptcy Code, a debtor-in-possession has the choice to assume or reject an unexpired lease. If the debtor chooses to assume the lease (continue the contract), they must take the contract ‘cum onere’ (with the burdens). This requires the debtor to cure any existing defaults (or provide a prompt cure) and provide ‘adequate assurance’ to the lessor that they will be able to fulfill future obligations under the lease terms.
Incorrect: The concept of ‘cherry-picking’ or selective assumption is prohibited; a lease must be assumed or rejected as a whole. Pre-petition arrears are not automatically waived; they must be cured if the lease is assumed. While ‘cramdown’ provisions exist for secured debts, they do not apply to ‘true leases’ where the lessor retains ownership; the debtor cannot unilaterally rewrite the lease into a secured loan to reduce the obligation to the asset’s fair market value.
Takeaway: To retain a lease in bankruptcy, a debtor must assume the contract in full, which requires curing all defaults and proving the ability to meet future obligations.
Incorrect
Correct: Under Section 365 of the Bankruptcy Code, a debtor-in-possession has the choice to assume or reject an unexpired lease. If the debtor chooses to assume the lease (continue the contract), they must take the contract ‘cum onere’ (with the burdens). This requires the debtor to cure any existing defaults (or provide a prompt cure) and provide ‘adequate assurance’ to the lessor that they will be able to fulfill future obligations under the lease terms.
Incorrect: The concept of ‘cherry-picking’ or selective assumption is prohibited; a lease must be assumed or rejected as a whole. Pre-petition arrears are not automatically waived; they must be cured if the lease is assumed. While ‘cramdown’ provisions exist for secured debts, they do not apply to ‘true leases’ where the lessor retains ownership; the debtor cannot unilaterally rewrite the lease into a secured loan to reduce the obligation to the asset’s fair market value.
Takeaway: To retain a lease in bankruptcy, a debtor must assume the contract in full, which requires curing all defaults and proving the ability to meet future obligations.