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Scope



                       Analysis

                       There are three components in the arrangement – the building assets (office and HVAC), the office
                       furniture, and the maintenance agreement.

                       The office and HVAC system are one lease component because they cannot function independently of
                       each other. The HVAC system was designed and tailored specifically to be integrated into the office
                       building and cannot be removed and used in another building without incurring substantial costs.
                       These building assets are a lease component because they are identified assets for which Customer
                       Corp directs the use.

                       The office furniture functions independently and can be used on its own. It is also a lease component
                       because it is a group of distinct assets for which Customer Corp directs the use.


                       The maintenance agreement is a nonlease component because it is a contract for service and not for
                       the use of a specified asset.

                       To properly account for the lease components, Customer Corp will need to determine the standalone
                       selling price of the use of the building assets, the office furniture, and the maintenance services. If the
                       sum of the standalone selling prices exceeds the monthly payment, the implicit discount provided for
                       bundling the three components should be allocated between the service and the lease elements based
                       on the relative standalone selling prices.


              2.5.1    Portfolio exception

                       A reporting entity may elect to utilize a portfolio approach, under which it does not have to consider
                       the lease components to apply lease accounting. Lessees and lessors may use the portfolio approach
                       for leases provided its application does not create a material difference when compared to accounting
                       for leases at the contract level. In addition to the materiality restriction, we would expect that a
                       reporting entity that applies the exception would be able to demonstrate that the leases being grouped
                       have similar characteristics. The leases should have comparable conditions regarding such clauses as
                       default, extensions, purchase options, and lease term. Common examples of leases that may meet this
                       criteria are office equipment (copiers, computers, phone systems with multiple handsets, etc.) or
                       vehicle fleets that have single start and end dates.

              2.5.2    Reallocation of consideration


                       Under specific circumstances a lessee should reallocate the consideration paid between components as
                       discussed in ASC 842-10-15-36.





















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