2 Accounting for investments in debt securities
Financial reporting developments Certain investments in debt and equity securities | 20
In establishing intent, an entity should consider its historical experience, such as sales and transfers of
debt securities classified as held to maturity. Past sales or transfers of held-to-maturity debt securities
are inconsistent with an expressed intent to hold debt securities to maturity. Refer to section 4, Transfers
between categories and sales of debt securities, for further discussion of sales and transfers of held-to-
maturity securities that would call into question or “taint” an entity’s assertion that it has the intent and
ability to hold the remaining portfolio to maturity.
When an entity assesses whether it has the intent and ability to hold debt securities to maturity, it does
not need to consider remote scenarios that it could not have anticipated, such as a run on a bank. We
believe that very few events would qualify for this exception.
2.3.4.1.1 Considerations for regulated entities
Regulators of financial institutions can, under certain circumstances, conclude that the continued
ownership of any asset represents an undue safety and soundness risk to an institution and, accordingly,
require a financial institution to dispose of that asset. The federal banking regulatory agencies note that
only in rare circumstances have examiners required a financial institution to dispose of mortgage securities
that have become high risk after acquisition. However, an examiner has the authority to require a
financial institution to dispose of any security or asset.
The FASB did not intend that a regulator’s overall divestiture authority be considered as an automatic
constraint of an institution’s ability to hold a debt security to maturity, because such a conclusion would
have precluded any use of the held-to-maturity category by regulated financial institutions. However, the
FASB recognized that facts and circumstances could indicate that an institution does not have the ability
to hold a debt security to maturity. Refer to section 4, Transfers between categories and sales of debt
securities, for a discussion of sales of held-to-maturity securities that would call into question (i.e., “taint”)
an entity’s assertion that it has the intent and ability to hold the remaining portfolio to maturity.
2.3.4.1.2 Considerations for specific instruments
2.3.4.1.2.1 Pledged securities
Companies often pledge debt securities as collateral to borrow funds at reduced interest rates. Such a
pledge can be consistent with an entity’s assertion that it has the intent and ability to hold the security to
maturity if the transaction is not considered a sale under ASC 860-10, and the entity intends and expects
to satisfy the obligation without surrendering the debt security. An entity should make an ongoing
assessment of the probability that the securities will be used to repay the related obligation. If the entity
determines that the securities will not be needed to repay the related obligation, the securities can be
classified as held to maturity, as long as the entity has the positive intent and ability to hold them to maturity.
If the transaction is considered a sale under ASC 860-10-40-5 and the held-to-maturity security is
transferred for a reason other than those specified in ASC 320-10-25-6, ASC 320-10-25-9 and ASC 320-
10-25-14, the transfer would taint the held-to-maturity portfolio. Refer to section 4, Transfers between
categories and sales of debt securities, for further guidance.
2.3.4.1.2.2 Repurchase agreements and similar arrangements
A held-to-maturity security can be subject to a repurchase agreement or a securities lending agreement as
long as the transaction is accounted for as a secured borrowing under ASC 860-20, and the entity intends
and expects to be able to satisfy the obligation and recover access to its collateral (ASC 320-10-25-18(e)).
A repurchase agreement that does not meet the criteria to be treated as a sale under ASC 860 is treated
as a collateralized borrowing (secured) transaction. ASC 320-10-25-18(e) states that a seller-borrower
can classify a debt security subject to a repurchase agreement accounted for as a secured borrowing
under ASC 860-20 as a held-to-maturity security, as long as the institution has the positive intent and
ability to repay the borrowing and recover access to its collateral.
Additional guidance related to ASC 860 can be found in our FRD, Transfers and servicing of financial assets.