GASB Review - 2012 The views expressed in this presentation are those of Messrs. Attmore and Bean. Official positions of the GASB are determined only after.

Slides:



Advertisements
Similar presentations
Statement No. 60: Accounting and Financial Reporting for Service Concession Arrangements.
Advertisements

IAS 19 vs. FAS158, 132R, 87, etc. versus. The scope is broad and includes wages, vacation or holiday pay, bonus, termination benefits, etc. as well as.
What an Examiner Should Know. U.S. GAAP - Then and Now Before September categories of U.S. GAAP Multiple promulgators of U.S. GAAP AICPA FASB After.
Overview of New Pension Accounting Requirements Under GASB Statements No. 67 and No. 68 September 2013.
Summary of GASB Updates  Effective Dates – Recently Issued GASB Standards  June 30, 2012  GASB Statement No. 64, Derivative Instruments: Application.
Chapter 2 Principles of Accounting and Financial Reporting for State and Local Governments McGraw-Hill/Irwin Copyright © 2013 by The McGraw-Hill Companies,
Chapter Seventeen Accounting for State and Local Governments (Part II) Copyright © 2015 McGraw-Hill Education. All rights reserved. No reproduction or.
GOVERNMENTAL ACCOUNTING’S “URBAN LEGENDS” CSFMO Oakland, California February 20,
©2009 KPMG LLP, the U.S. member firm of KPMG International, a Swiss cooperative. All rights reserved. 1 Business Combinations: What you need to know about.
1 GASB 68 Accounting and Reporting for Pensions an Amendment of GASB Statement No. 27 Presented by: Kevin S. Wong, CPA Gilbert Associates, Inc.
1.  2013  Statement 60 – Service Concession Arrangements  Statement 61 – Reporting Entity  Statement 62 – Codification of AICPA and FASB  Statement.
GASB Update AGFOA April, Overview Statement 61 – Reporting Entity Omnibus Statement 62 – Pre-89 FASB and AICPA Pronouncements Statement 63 – Financial.
Pension Reporting and Other Accounting and Audit Updates Matt Geerdes Crowe Horwath LLP Andy Mace Miller, Cooper.
CACUBO 2012 ANNUAL MEETING GASB UPDATE Presented by: Matthew Pehle, CPA Sikich LLP 1415 W. Diehl Road Suite 400 Naperville, IL (630)
GASB Update The views expressed in this presentation are those of Mr. Sundstrom. Official positions of the GASB are determined only after extensive due.
California Society of Municipal Finance Officers GASB Update The views expressed in this presentation are those of Mr. Bean. Official positions of the.
Chapter 8 Interests In Joint Ventures © 2009 Clarence Byrd Inc. 2 Joint Venture Defined  Paragraph (c) A joint venture is an economic activity.
Technical Update Presented by Chris Ray Partner - KPMG LLP KPMG LLP.
© 2008 Clarence Byrd Inc. 2  Not-for-profit organizations normally do not have a transferable ownership interest.
Florida Government Finance Officers Association Webinar GASB’s New Pension Standards December 18, 2014.
McGraw-Hill/Irwin Governmental Entities: Introduction and General Fund Accounting 17 Copyright © 2009 The McGraw-Hill Companies, Inc. All rights reserved.
Changes in Accounting and Reporting for Pensions Presented to Senate Finance Committee _____________________________________.
Pension Accounting and Financial Reporting GASB Invitation to Comment The views expressed in this presentation are those of Mr. Bean. Official positions.
Intermediate Accounting
Accounting Clinic VII McGraw-Hill/Irwin Copyright © 2013 by The McGraw-Hill Companies, Inc. All rights reserved.
Auxiliary Organizations GASB Statement No. 68 Accounting and Financial Reporting for Pensions Sheralin Klinthong, Associate Director, FS / SFSR Chancellor’s.
GASB Statement No. 34 Cliff Notes Laurie L. Piccirillo, Business Manager Brockway Area School District Dr. David M. Piper, Assistant to Superintendent.
California Society of Municipal Finance Officers Pension Accounting and Financial Reporting: A Work in Progress The views expressed in this presentation.
GASB Technical Update Mark Thomas KPMG LLP Year-End GAAP Training April 18, 2014.
April 8, Statement No. 65, Items Previously Recorded as Assets and Liabilities Statement No. 67, Financial Reporting for Pension Plans-an amendment.
GASB Update Lisa R. Parker, CPA
29 th Annual LA GFOA Fall Conference October 4, 2012 Baton Rouge Crowne Plaza Presented by Tim Green, CPA Allen, Green & Williamson, LLP.
©2013 CliftonLarsonAllen LLP cliftonlarsonallen.com See CLA PowerPoint User Guide for instructions to insert an image or change the icon on the business.
The National Association of State Auditors, Comptrollers and Treasurers GASB Update: Keeping Pace in a Changing Environment April 14, The views.
GASB Update California Society of Municipal Finance Officers February 21, 2013 Michelle Czerkawski, GASB Project Manager The views expressed in this presentation.
Pension Accounting GASB Pension Accounting and Financial Reporting - Overview SAAABA Annual Business Seminar– April 18, 2012 Cindy Peters – Accountant.
Copyright © 2014 by The Segal Group, Inc. All rights reserved. GASB Statements 67 & 68 – Audit & Budget Committee Discount Rate and Allocation of Assets/Liabilities.
Presented by Frank Crawford, CPA President, Crawford & Associates, P.C. (twitter) 1.
GASB Standards on Pensions
GASB UPDATE Presented by:Brian A. Ritschel, CPA Manager 1.
GASB’s New & Upcoming Standards A Governmental Audit Quality Center Web Event September 28, 2011 The views expressed in this presentation are those of.
National State Auditors Association GASB Update The views expressed in this presentation are those of Messrs. Attmore and Bean. Official positions of the.
1 Your Tilted Balance Sheet – GASB 68 Overview Presented by: Kevin S. Wong, CPA Gilbert Associates, Inc. September 12, 2013.
Public Pension Financial Forum Annual Conference GASB Update: The GASB Has Been Busy The views expressed in this presentation are those of Mr. Bean. Official.
Govt. Reporting - 1 GOVERNMENTAL REPORTING City Council Budgetary Hearing.
IAS 7: Cash Flow Statements. Agenda 1.Objective and Scope 2.Definitions 3.Direct and Indirect method 4.Operating activities, Investing activities, Financing.
Requirements of the Standard IAS 7
Presented by: G.S. Curran & Co. GASB 68 FOR COST SHARING EMPLOYERS OF THE ASSESSORS’ RETIREMENT FUND.
Florida GFOA Hot Topic Implementation of GASB Standards The views expressed in this presentation are those of Mr. Bean. Official positions of the GASB.
Unit 6 Seminar Accounting for Postemployment Benefits.
(C) 2007 Prentice Hall, Inc.2-1 The Balance Sheet-Liabilities and Shareholders’ Equity “Old accountants never die; they just lose their balance” --Anonymous.
1 GASB Update (No catchy subtitle – my bad) Yvonne Clayborne March 11, 2016.
Governmental Accounting Pensions and Other Postemployment Benefits Local Government Corporation.
Financial Reporting and Auditing - GASB Update Krista Edoff, Partner.
April 14, 2016 TECHNICAL UPDATE Mark Thomas, Partner, KPMG LLP.
Presented by: Chris Pembrook, CPA, MBA, CGAP, Cr.FA Frank Crawford, CPA @fcrawfordcpa.
Copyright © 2016 by The Segal Group, Inc. All rights reserved. MGFOA Annual Meeting 2016 OPEB and GASB 74/75 May 11, 2016 Daniel J. Rhodes, FSA, MAAA Vice.
GASB’s OPEB Changes - Will they impact public sector health care benefits? November 7, 2014 Eric Gary, FSA, FCA, MAAA Chief Health Actuary.
GASB 74 and 75: Other Post-Employment Benefits (OPEB)
GASB Update (No catchy subtitle – my bad)
Accounting for Postemployment Benefits
OPEB Just Like Pensions but Not! October 12, 2017
Other Post Employment Benefits
10/28/2014 The Municipal Analysts Group of New York What’s New With the GASB and What Does It Mean for Municipal Credit? Mr. Bean.
Beth Wright Managing Director
GASB Update Presented by:
Accounting for Assets Cash Flows.
Pension Regulations Presented by David Maccoux, CPA, Shareholder
GASB Update WGFOA Winter Conference
GASB Update and a few other things
Presentation transcript:

GASB Review The views expressed in this presentation are those of Messrs. Attmore and Bean. Official positions of the GASB are determined only after extensive due process and deliberation.

Moderator R. Kinney Poynter Executive Director NASACT Speaker Robert H. Attmore Chair GASB Speaker David R. Bean Director of Research GASB Opening Remarks Website:

Intentionally Left Blank

Current Board Members Member Bob Attmore, Chair Jim Brown Bill Fish Michael Granof David Sundstrom Jan Sylvis Marcia Taylor Term Ends June —first term 2016—first term 2015—first term 2014—first term

Effective Dates—June  Statement 57, paragraph 8—Agent OPEB Plans  Statement 59—Financial Instruments Omnibus  Statement 64—Derivative Terminations 2013  Statement 60—Service Concession Arrangements  Statement 61—Reporting Entity  Statement 62—Codification of AICPA and FASB  Statement 63—Deferrals Presentation 2014  Statement 65—Assets and Liabilities—Reclassification and Recognition  Statement 66—Technical Corrections  Statement 67—Pension Plans 2015  Statement 68—Pension Accounting for Employer and Nonemployer Contributing Entities 5

2012

Statement 59 Financial Instruments Omnibus

What Do You Need to Know About Statement 59? Statement 31, is clarified to indicate that a 2a7-like pool is an external investment pool that operates in conformity with the Securities and Exchange Commission’s (SEC) Rule 2a7 as promulgated under the Investment Company Act of 1940, as amended. Statement 40 is amended to indicate that interest rate risk information should be disclosed only for debt investment pools—such as bond mutual funds and external bond investment pools—that do not meet the requirements to be reported as a 2a7-like pool. Statement 53 is amended to clarify certain provisions. 8

What Are the Statement 53 Clarifications? Net settlement characteristic that defines a derivative instrument is not met by a contract provision for a penalty payment for nonperformance Financial guarantee contracts included in the scope are limited to those that are considered to be investment derivative instruments entered into primarily for the purpose of obtaining income or profit Certain contracts based on specific volumes of sales or service revenues are excluded from the scope One of the "leveraged yield" criteria is met if the initial rate of return on the companion instrument has the potential for at least a doubled yield. 9

2013

Statement 60 Service Concession Arrangements

Service Concession Arrangements (SCAs) SCAs are a type of public-private or public- public partnership. The term public-private partnership is used to refer to a variety of:  Service arrangements  Management arrangements  SCAs. 12

Scope The transferor conveys to the operator the right and related obligation to provide public services through the operation of a capital asset in exchange for significant consideration, such as an up-front payment, installment payments, a new facility, or improvements to an existing facility. The operator collects and is compensated from fees from third parties The transferor determines or has the ability to modify or approve what services the operator is required to provide, to whom the operator is required to provide the services, and the prices or rates that can be charged for the services. The transferor is entitled to significant residual interest in the service utility of the facility at the end of the arrangement 13

Reporting Facilities If the facility associated with an SCA is a new facility purchased or constructed by the operator, or an existing facility that has been improved by the operator, then the transferor should report  The new facility or the improvement as a capital asset at fair value when it is placed in operation, with  Any contractual obligations recorded as liabilities, along with a corresponding deferred inflow of resources, 14

Reporting Upfront or Installment Payments Transferor should report the up-front payment or present value of installment payments as an asset and any contractual obligations recorded as liabilities along with a related deferred inflow of resources. Revenue should be recognized as the deferred inflow of resources is reduced. This revenue should be recognized in a systematic and rational manner over the term of the arrangement beginning when the facility is placed into operation. 15

Recognition of Liabilities Liabilities associated with the SCA should be recorded at their present value if a contractual obligation is significant and meets either of the following criteria:  The contractual obligation directly relates to the facility (for example, obligations for capital improvements, insurance, or maintenance on the facility). This obligation could relate to ownership of the facility or could arise from the transferor’s responsibility to assure that the facility remains fit for the particular purpose of the arrangement.  The contractual obligation relates to a commitment made by the transferor to maintain a minimum or specific level of service in connection with the operation of the facility (for example, providing a specific level of police and emergency services for the facility or providing a minimum level of maintenance to areas surrounding the facility). 16

Statement 61 The Financial Reporting Entity—Omnibus

Overview The most significant effects of the amendments are to:  Increase the emphasis on financial relationships Raises the bar for inclusion  Refocus and clarify the requirements to blend certain component units  Improve the recognition of ownership interests Joint ventures Component units Investments 18

Inclusion Criteria Statement 14 requires inclusion if Potential Component Unit is fiscally dependant. That is, Primary Government has authority over:  Budget, or  Setting taxes and charges, or  Issuing debt Statement 61 adds a requirement for a financial benefit or burden before inclusion is required. 19

Inclusion Criteria Statement 14 requires inclusion of a Potential Component Unit if exclusion would make reporting entity’s statements “misleading or incomplete” Statement 61 eliminates “incomplete,” and emphasizes that the determination would normally be based on financial relationships  Such as significant financial benefit to/burden on the Primary Government that is other than temporary 20

Blending Requirements Statement 14 requires blending if Primary Government and Component Unit have “substantively the same” governing body Statement 61 expands that requirement to also include:  A financial benefit/burden relationship, or  Primary Government has “operational responsibility” for Component Unit Primary Government ’s personnel manage activities of Component Unit like a fund, program, or department of the primary government 21

Blending Requirements The blending criteria is broadened to include component units whose total debt outstanding is expected to be repaid entirely or almost entirely by revenues of the primary government  Even if the component unit provides services to constituents or other governments, rather than exclusively or almost exclusively to the primary government 22

Blending Requirements Clarifies that the funds of a blended Component Unit have the same characteristics, reporting alternatives, and limitations as those of the Primary Government  Major fund reporting  Could be combined with other funds for display 23

Blending Requirements Clarifies how to blend component units in a business-type activity (BTA) reporting model: In the three basic statements:  For a multiple column BTA Additional column(s), as if funds of the Primary Government  For a single column BTA Consolidate Component Unit data into the single column  Present combining information in the notes Additional column(s), with Primary Government total column 24

Major Component Units Clarifies the types of relationships that should generally affect the major Component Unit determination:  Primarily financial relationships Significant transactions with the Primary Government Significant financial benefit/burden relationship  Could be based on the nature of services provided by Component Unit Eliminates consideration of each Component Unit’s significance relative to other Component Units 25

Reporting Equity Interests An asset should be recognized for an equity interest in:  A joint venture  A partnership  An investment  A component unit If the component unit is blended, the equity interest is eliminated in the blending process Minority interests would be classified in net assets as “Restricted, nonexpendable” Recognition and Measurement is based on Joint Venture equity interest requirements in Statement 14 26

Note Disclosures Clarifies that current disclosures require:  Rationale for including each component unit  Whether it is discretely presented, blended, or included as a fiduciary fund (Practical consideration: Can aggregate similar Component Units for disclosure) No new disclosures 27

Statement 62 Codification of Pre-November 30, 1989 FASB and AICPA Pronouncements

Five Classifications Conflict with or contradict GASB standards  FASB Statement No. 4—Gain or loss on debt extinguishments  FASB Statement No. 43—Compensated absences Are not applicable to governments  FASB Statement No. 84—Convertible debt Rarely applicable (excluded)  FASB Statement No. 19–Oil and Gas Are applicable to governments  FASB Statement No. 5—Contingencies  FASB Statement No. 34—Capitalization of interest Will be addressed in GASB projects (applicable, but excluded)  APB Opinion 16—Business combinations 29

Basic Guidance Statement 20 is superseded  All applicable pre-11/30/89 standards are contained in the GASB’s codification  All potentially applicable post-11/30/89 non-GASB standards will be “other accounting literature” Guidance on 29 topics is brought into the GASB literature 30

Significant Topics Special and extraordinary items (APB Opinion 30) Comparative financial statements (ARB 43) Related parties (FASB Statement 57) Prior-period adjustments (FASB Statement 16 and APB Opinion 9) Accounting changes and error corrections (APB Opinion 20 and FASB Interpretation 20) Contingencies (FASB Statement 5 and FASB Interpretation 14) Extinguishments of debt (APB Opinion 26 and FASB Statement 76) Inventory (Accounting Research Bulletin 43) Leases (FASB Statements 13, 22, and 98 and FASB Interpretations 23, 26, and 27) 31

Specialized Topics Sales of real estate (FASB Statement 66) Real estate projects (FASB Statement 67) Research and development arrangements (FASB Statement 68) Broadcasters (FASB Statement 63) Cable television systems (FASB Statement 51) Insurance enterprises (FASB Statement 60) Lending activities (FASB Statement 91) Mortgage banking activities (FASB Statement 65) Regulated operations (FASB Statements 71, 90, and 101) 32

Early Implementation— What are the Issues? GASB Statement 20, paragraph 7 option Guidance for government combinations FASB/IASB lease project 33

Statement 63 Financial Reporting of Deferred Outflows of Resources, Deferred Inflows of Resources, and Net Position

Background Concepts Statement 4 identifies 5 elements that make up a statement of financial position:  Assets  Liabilities  Deferred outflows of resources  Deferred inflows of resources  Net position This differs from the composition currently required by Statement 34, which requires the presentation of assets, liabilities, and net assets in a statement of financial position 35

Definitions Deferred outflows of resources  A consumption of net assets by the government that is applicable to a future reporting period  Has a positive effect on net position, similar to assets Deferred inflows of resources  An acquisition of net assets by the government that is applicable to a future reporting period  Has a negative effect on net position, similar to liabilities Net position  The residual of all elements presented in a statement of financial position  = assets + deferred outflows – liabilities – deferred inflows 36

Display Requirements Deferred outflows should be reported in a separate section following assets Similarly, deferred inflows should be reported in a separate section following liabilities Net Position components resemble net asset components under Statement 34, but include the effects of deferred outflows and deferred inflows  Net investment in capital assets  Restricted  Unrestricted Governmental funds continue to report fund balance 37

Disclosures Provide details of different types of deferred amounts if components of the total deferred amounts are obscured by aggregation on the face of the statements If the amount reported for a component of net position is significantly affected by the difference between deferred inflows or outflows and their related assets or liabilities—provide an explanation in the notes 38

Deferred Outflows/Inflows Statement 53—Accounting and Financial Reporting for Derivative Instruments Statement 60—Service Concession Arrangements 39

Intentionally Left Blank

2014 and 2015

Statement 65 Items Previously Reported as Assets and Liabilities

Deferred Inflows of Resources Grants received in advance of meeting timing requirement Deferred amounts from refunding of debt (credits) Proceeds from sales of future revenues Deferred gain from sale-leaseback “Regulatory” credits 43

Deferred Outflows of Resources Grant paid in advance of meeting timing requirement Deferred amounts from refunding of debt (debits) Cost to acquire rights to future revenues (intra-entity) Deferred loss from sale-leaseback 44

Outflows of Resources Debt issuance costs (other than insurance) Initial costs incurred by lessor in an operating lease Acquisition costs for risk pools Loan origination costs 45

Inflows of Resources Loan origination fees Commitment fees (after exercise or expiration) 46

Statement 66 Technical Corrections—2012

Conflicts Statement 62 with  Statement 13—Leases  Statement 48 Purchase of a loan or group of loans Servicing fees related to mortgage loans Statement 10 with  Statement 54—Risk financing pools 48

49 Other Projects in Process Pension Accounting and Reporting (Plan and Employer EDs) Conceptual Framework—Recognition and Measurement (PV) Economic Condition Reporting—Financial Projections (PV) Government Combinations (ED) Financial Guarantees—ED issued in June Fair Value—Definition and Application Other Postemployment Benefits GAAP Hierarchy 49

Pension Accounting and Reporting

Pension Project Timeline Staff research completed in 2008 Invitation to Comment issued in 2009 Preliminary Views issued in 2010 Two Exposure Drafts approved in June 2011 Deliberations based on responses has begun Final standards were approved in June

Basics Pension benefits originate from exchanges between the employer and employees of salaries and benefits for employee services and are part of the total compensation for employee services Obligations for pensions meet the definition of a liability in Concepts Statement 4  Liabilities are present obligations to sacrifice resources that the government has little or no discretion to avoid Compensation expense should be recognized in the period employee services are provided 52

Fundamental Approach View the cost of pensions within the context of an ongoing, career-long employment relationship Use an accounting-based versus funding-based approach to measurement and report any Net Pension Liability on the statement of financial position 53

Total Pension Liability Measurement

40 Basic Three-Step Measurement Approach ) Project Benefit Payments 2) Discount Future Payments Present Value of Payments 3) Attribute to Service Periods

Actuarial Assumptions Selection of all actuarial assumptions should be made in accordance with Actuarial Standards of Practice (unless specific guidance is provided by the GASB). 56

Projection of Benefits The projection of pension benefit payments should include the effects of projected future salary increases and future service credits, if part of the benefits formula, as well as automatic COLAs Ad hoc COLAs would be incorporated into projections of pension benefit payments only if an employer’s practice indicates that the COLAs are substantively automatic 57

Discount Rate Should be a single rate that reflects:  The long-term expected rate of return on plan investments that are expected to be used to finance the payment of benefits to the extent that Plan net position is projected to be sufficient to make projected benefit payments, and Assets are expected to be invested using a strategy to achieve that return  A yield or index rate for 20-year, tax exempt general obligation bonds with an average rating of AA/Aa or higher to the extent that the conditions for the use of the long-term expected rate of return are not met 58

Crossover Point Plan Net Position Future Contributions and Investment Earnings Benefit Payments and Administrative Costs Crossover Point Years

Attribution Method Single actuarial cost allocation method:  Based on entry age normal principles  Applied as a level percentage of payroll  Over periods beginning in first period in which the employee’s services lead to benefits under the plan (without regard to conditional service-related provisions such as vesting) and ending in last period of the employee’s service 60

Timing and Frequency of Measurement The net pension liability is measured as of a date (the measurement date) no earlier than the end of its prior fiscal year, consistently applied from period to period Total pension liability component of the net pension liability at the measurement date is determined either by  An actuarial valuation as of that date or  The use of update procedures to roll forward amounts to the measurement date from an actuarial valuation as of a date no more than 30 months (plus 1 day) prior to the fiscal year-end For financial reporting purposes, actuarial valuations at least biennially  More frequent valuations are encouraged 61

Plan Net Position Measurement

Measurement of Plan Assets In calculating the employer’s net pension liability, plan net position should be measured in the same way as measured in the plan’s statement of plan net position, including measurement of investments at fair value. 63

Pension Expense Measurement

Immediate Expense Recognition Expense recognition would be immediate for:  Pension benefits earned during the reporting period (service cost or normal cost)  Interest cost on the total pension liability  Changes in benefit terms that affect the total pension liability 65

Deferred Expense Recognition Expense would be deferred and recognized over a period equal to the average remaining service periods of active and inactive (including retirees) employees for:  Differences between expected and actual changes in economic and demographic factors  Changes in assumptions about economic and demographic factors Differences between actual and projected earnings on plan investments would be deferred and recognized as pension expense over a five-year, closed period 66

Governmental Funds Recognition

Modified Accrual Net pension liabilities are normally expected to be liquidated with expendable available financial resources to the extent that pension benefits have matured—that is, pension benefit payments are due and plan net position is not sufficient for payments of benefits. Liabilities to defined benefit pension plans, as well as liabilities for defined contribution pensions, are normally expected to be liquidated with expendable available financial resources when amounts are due pursuant to contractual arrangements or legal requirements. 68

Cost-Sharing Multiple Employer Plans

Cost-Sharing Employers A government participating in a cost-sharing plan would report a liability in its own financial statements that is equivalent to its proportionate share of the net pension liability of all the employers in the cost-sharing plan. Approach uses a basis for allocation of proportionate share based on the employer’s expected contribution effort relative to that of all contributors 70

Special Funding Situations Nonemployer Reporting

Nonemployer Entities If contributions directly to the pension plan are legally required, the nonemployer contributing entity’s requirement to contribute should be viewed as an assumption of some (or all of) the collective net pension liability of the employers. The nonemployer contributing entity’s contributions generally should be assumed to be associated with current-period service cost and past service cost in the same proportions as employer contributions are assigned to those amounts  Exception—effective plan terms indicates that the nonemployer entity’s contributions should be allocated differently. If the nonemployer entity is the only entity that is required to make contributions, the nonemployer contributing entity should report its involvement as an assumption of the collective net pension obligation of the employer(s). 72

Research Agenda Electronic Financial Reporting Fiduciary Responsibilities Leases Tax Abatement Disclosures 73

Moderator R. Kinney Poynter Executive Director NASACT Speaker Robert H. Attmore Chair GASB Speaker David R. Bean Director of Research GASB Questions? Website:

Intentionally Left Blank