Asset Evaluation Re: FASB 158

[Andy the Actuary]

A calendar year fiscal year credit union client must complete and file year end financial reporting in the first week of January. Thus, for example, 12/31/2008 FASB 158 disclosures must be completed by say January 5, 2009. We can wink and determine the discount rate a week or so before 12/31 so can have the FASB 158 spreadsheet ready for completion once year-end assets are known.

The assets that are traded on the usual markets can be easily evaluated. But, what about limited partnerships, real-estate trusts, etc. whose evaluations may have a 30+ day lag?

Is anyone able to shed light as to what major accounting firms have commented? For example, if evaluations have a 30-day lag, would it be acceptable to use an October 31 valuation for such investments?

The dilemma here is that if you're not going to comply with FASB 158 to the letter, why not simply continue to measure assets/liabilities as of an earlier date or use a hybrid, such as assets as of 9/30, liabilities as of 9/30 but valued using a 12/31 discount rate? What are the repercussions of the auditor commenting that FASB 158 has been applied in a way that complies with the statement?

What have you kids in the peanut gallery worked out with your clients and their auditors?