The complex crypto landscape
On the heels of the SEC staff publishing its sample letter with crypto asset disclosure requirements, the accounting for crypto assets was touched on by Munter, with more depth being provided by Jonathan Wiggins (OCA staff). While acknowledging the lack of specific guidance and diversity in practice, both Munter and Wiggins made the point that existing guidance can usually be applied by analogy to determine the appropriate accounting for the economics of the arrangement.
They reminded the audience of the unique risks associated with crypto assets, along with the requirements of SAB 121, which lays out the accounting by custodians of crypto assets, under both US GAAP and IFRS® Accounting Standards. Read more about the application of SAB 121 here.
The bigger news was crypto asset lending arrangements. Wiggins laid out the expectation that a crypto lending arrangement that has the economics of a traditional lending agreement be accounted for using similar accounting as traditional lending – including the recognition of a valuation allowance under ASC 326 to reflect counterparty credit risk. While mentioning the need for disclosures under the lending standards, he also referred to ‘additional’ disclosures that adequately describe the nature of the crypto arrangement.