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Effective date and transition

10.8 Amounts previously recognized in business

combinations

ASC 842-10-65-1 provides guidance for reporting entities that have previously recognized an asset or a
liability related to favorable or unfavorable terms of an operating lease under the business
combination guidance in ASC 805.

ASC 842-10-65-1(h)
If an entity has previously recognized an asset or a liability in accordance with Topic 805 on business
combinations relating to favorable or unfavorable terms of an operating lease acquired as part of a
business combination, the entity shall do all of the following:

1. Derecognize that asset and liability (except for those arising from leases that are classified as
operating leases in accordance with Topic 842 for which the entity is a lessor).

2. Adjust the carrying amount of the right-of-use asset by a corresponding amount if the entity is a
lessee.

3. Make a corresponding adjustment to equity if assets or liabilities arise from leases that are
classified as sales-type leases or direct financing leases in accordance with Topic 842 for which the
entity is a lessor. Also see (w).

10.9 Five-year selected financial data table

We believe that the selected financial data table required by Item 301 of Regulation S-K should follow
the transition provisions of the new leases guidance. Adjustments would only be required to those
periods in the financial data table that correspond to the periods adjusted in the registrant’s financial
statements included in the relevant filing. For example, a calendar year-end SEC registrant that is
neither an emerging growth company nor a smaller reporting company will have a Form 10-K for the
year ending December 31, 2019 that will include financial statements for each of the three years in the
period ending December 31, 2019 and selected financial data for each of the five years in the period
ending December 31, 2019. Assume that the entity elects to adjust comparative periods presented.
January 1, 2017 is the beginning of the earliest comparative period presented in the financial
statements. Accordingly, the registrant would only apply the new standard to 2019, 2018, and 2017 in
the selected financial data table. The selected financial data for 2016 and 2015 are not considered
comparative financial statements and therefore do not change the date of initial application of the new
leasing standard for purposes of GAAP. The 2016 and 2015 information included in the selected
financial data table will be prepared using the prior lease accounting model.

Similarly, if a reporting entity chooses not to adjust comparative periods, the four prior years in the
selected financial data table would not be adjusted.

In either case, consistent with Instruction 2 to SEC Regulation S-K Item 301, the registrant must
provide disclosure regarding the lack of comparability of the data presented in the selected financial
data table (if applicable and material).

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