How are the floor and ceiling limits calculated as per the lower of cost or market LCM method under US GAAP?

Although most CPAs know that inventory should be valued at the lower of cost or market (LCM) under U.S. GAAP, many do not realize the difficulties that might arise when trying to apply the LCM rules. Overcoming these difficulties can be quite challenging, even for those with experience. The following is a review of the current rules surrounding inventory valuation, highlighting some of the problems faced when applying the LCM rules (including the potential impact on the financial statements) and providing some practical suggestions for implementing them in accordance with U.S. GAAP. The Basics of LCM The cost of unsold inventory is an asset, and normally it becomes an expense only when the inventory is sold; however, when there is evidence that the utility of inventory will be less than its cost, the inventory must be written down to a lower value (ASC 330-10-35-1). Requiring a write-down prior to the sale of inventory results in a charge against income in the period when the decline in value becomes evident, rather than delaying that charge until the period when the inventory is sold, and avoids overstating the value of the impaired inventory on the balance sheet. The term "market" is generally not intended to represent sales value, but rather the purchase price or cost of reproduction; it is best thought of in terms of the equivalent expenditure that would have to be made in order to procure corresponding utility at the balance sheet date (ASC 330-10-35-3). Thus, although the phrase "lower of cost or market" is commonly used, it is probably more accurate to describe the procedure as "lower of original cost or replacement cost." Under U.S. GAAP, there are boundaries on the market value, based on the exit value to the entity (i.e., the sales price). If replacement cost exceeds the net realizable value (NRV), the NRV should be used as the market value. The NRV equals the estimated selling price minus estimated costs of completion and disposal, and it is commonly referred to as the "ceiling." If replacement cost is less than the "floor" (i.e., the NRV minus an allowance for a normal profit margin), then the floor should be used as the market value. Thus, the market value is interpreted as the replacement cost, with the additional requirements that market value cannot be more than the ceiling or less than the floor. Several estimates which vary in their degree of subjectivity and include replacement cost, sales price, costs of completion and disposal, and normal profit margin--are required to apply the LCM rules. Although these estimates should be made from a neutral standpoint, reporting entities might inappropriately manipulate them in order to manage the potentially significant financial statement impact of inventory write-downs. A detailed discussion of these topics is outside the scope of this article; thus, the examples discussed later assume that the estimated amounts needed to determine the final inventory values are given. To summarize the LCM process, one must first determine the replacement cost, ceiling, and floor for each inventory item. Next, one should choose the market value (i.e., designated market value [DMV]) from these three values by applying the rules discussed above; this is most easily done by ranking the three values from largest to smallest and selecting the median value as the DMV. The DMV is then compared to the inventory cost currently on the books, which is normally the original cost, unless a previous adjustment has been made to the cost basis of the inventory. The lower value is used as the inventory value at the balance sheet date. If cost is less than or equal to the DMV, no adjusting entry is necessary; if the DMV is less than cost, a write-down of the inventory is required. The LCM rule is one-sided--that is, it allows inventory to be valued at market only if the market value is lower than cost. U.S. GAAP (ASC 330-10-35-15) generally prohibits valuing inventory above cost, although doing so is allowed in special cases (which are not discussed in this article). Furthermore, if a write-down is required under the LCM rule, it creates a new cost basis for the inventory, and the reduced amount is to be considered the cost for subsequent accounting purposes (ASC 330-10-35-14). Companies may apply the LCM rule on an individual-item basis or to a combined level of inventory (i.e., the entire inventory or major categories of inventory). The aggregation basis used depends upon the nature of the inventory, and the method used should be the one that most clearly reflects periodic income (ASC 330-10-35-8). U.S. GAAP indicates a general preference toward applying the LCM rule on an individual-item basis, especially for nonmanufacturers; however, for companies that utilize several different inventory items in combination (i.e., manufacturers) to create a given end product, it might be more appropriate to combine those inventory items for purposes of the LCM calculation. Aggregation of inventory items might be proper when no loss of income is expected to occur as a result of a decline in the value of some items because other items--components of the same finished product--have a market value that is in excess of cost. Whichever method of aggregation is used, it should be applied consistently from year to year (ASC 330-10-35-10). Practical Considerations When Applying LCM Although many concerns must be considered when applying LCM, this discussion focuses on the following two implementation decisions: * Whether LCM should be applied to individual items or at an aggregate level * Whether the inventory detail should be adjusted to reflect any write-downs, as opposed to using an allowance account and not adjusting the inventory detail. A simple, two-year example is used to demonstrate the financial statement effects of each of these choices. It is assumed that the DMV for each inventory item has already been determined; thus, detailed information regarding the replacement cost ceiling, and floor for each item is not provided. Example: Year One

Formed in 2011, Bravis Co. is a retailer (nonmanufacturer) that sells only two items, A and B. Assume that Bravis uses a perpetual inventory system and the first-in, first-out (FIFO) inventory valuation method. Information for purchases, sales, and costs of each item for 2011 is shown in Exhibit 1.

EXHIBIT 1 Information for Purchases, Sales, and Costs (2011) Item Unit Unit Units Units Units on 2011 Totals Cost DMV Purchased Sold hand at COGS * (per at Dec. detail) Dec. 31,2011 at Dec. 31, 31,20111 2011 [dagger] A $20 $ 16 2,500 2,000 500 $40,000 $10,000 B $ 6 $ 7 5,000 4,200 800 $25,200 $ 4,800 Total $65,200 $14,800 Item Total DMV at Individual Dec. 31, LCM at Dec. 2011[double 31,2011 dagger] A $ 8,000 $ 8,000 B $ 5,600 $ 4,800 Total $13,600 $12,800 * A: 2.000 at $20 = $40.000 [dagger] A: 500 at S20 = $10,000 [double dagger] A: 500 at $16 = $8.000 B: 4,200 at $6 = $25,200 B: 800 at $6 = $4,800 B: 800 at $7 = $5,600 Individual-item approach. Under the individual-item approach, Bravis chooses the lower of cost or DMV for each individual item when determining the inventory valuation at 2011 year-end (December 31, 2011). Thus, the recorded value of item A must be reduced from the existing amount of $10,000 to its DMV of $8,000 (a $2,000 Suction). The excess of DMV over cost for Item B is disregarded.

What account should be debited to record the $2,000 write-down? Although cost of goods sold (COGS) might be debited, doing so is technically inaccurate, because the merchandise that triggered the write-down has not been sold but is still on hand. The alternative is to charge a separate loss account, appropriately labeled to disclose to readers the nature of the loss (e.g., loss from write-down of inventory to market value). Although both methods have the same effect on net income, the latter approach is conceptually preferable because it shows the loss separate from COGS in the income statement. Assume, for now, that the inventory account (rather than an allowance account) is credited, and that the inventory detail is adjusted to reflect the $16 unit value for Item A. Based on these facts and assumptions, Bravis would make the following journal entry at December 31, 2011:

Loss from Write-Down of 2,000 Inventory to Market Value Inventory 2,000

For reference purposes, the results (summarized below) of the individual-item approach, without the use of an allowance account, are referred to as the "year one benchmark":

Cost of Goods Sold $65,200 Loss from Write-Down of $ 2,000 Invento to Market Value Inventory at Dec. 31, 2011 $12,800

For a company with thousands of inventory items and numerous write-downs, it might be impractical to adjust the detailed records. To avoid this task, an allowance account (a contra-inventory account) may be used to capture the effect of the writedown on inventory. At first glance, the decision about whether to use an allowance account would seem to have no effect on the other side of the write-down entry; however, in future years (beyond year one), the entry to the allowance will be a net number that captures the effect of 1) new inventory write-downs, which should be debited to a loss account, and 2) adjustments for sales of inventory items in the current year that were written down in a prior year, which should be credited to COGS. (The inventory detail was not adjusted, so COGS will be overcharged when these items are sold.) Separating this entry into its components (COGS versus a loss from new write-downs) would be quite complex and would require the company to keep track of detailed information on prior write-downs; this level of detailed recordkeeping would defeat the purpose of using an allowance account. For this reason, when using an allowance account, assume that the other side of the adjusting entry will be entirely to COGS (rather than to a loss account or to some combination of the two accounts). Based on these assumptions, Bravis would make the following journal entry at December 31, 2011:

COGS 2,000 Allowance to Reduce Inventory to Market Value 2,000 For this example. the principal consequence of using an allowance account, as compared to the year one benchmark, is that the $2,000 loss from the write-down of inventory will be included with COGS. Them is no effect on the net value shown for inventory on the balance sheet ($12,800 = $14,800 - $2,000 allowance). Aggregate approach. Because Bravis is not a manufacturer, use of the aggregate approach is probably not appropriate; however, this example can still demonstrate the mechanics of the calculation, the necessary journal entry, and the effects on the financial statements. Under the aggregate approach, Bravis first determines the value of the entire inventory, at both cost and market, then compares the two values. Because the DMV ($13,600) is less than cost ($14,800), a $1,200 write-down is required. How might the $800 difference (with respect to the individual item approach) be explained? One could contend that the aggregate approach limits the amount of the write-down for Item A, to the extent that the market value of Item B is above cost. For example, perhaps all 500 units of Item A were written down by $2.40 (rather than $4) per unit, or 300 units of Item A were written down by $4 per unit (and the other 200 units remain at their cost of $20 per unit). Alternatively, one could say that the aggregate approach requires a hill write-down for Item A but allows for the write-up in value of the 800 units of Item B by $1 per unit. Regardless of how the details are construed, the latter explanation is fundamentally correct; inventory value at December 31, 2011, is $800 higher than it would otherwise have been, because the market value of Item B is $800 above cost. Thus, despite the stated prohibition under U.S. GAAP, the aggregate method implicitly permits some inventory to he valued at an amount greater than cost.

As this demonstrates, the allocation of any write-down (or write-up) to specific inventory items is arbitrary under the aggregate approach. For this reason, the use of an allowance account, with no adjustment to the inventory detail, is the only feasible alternative when using this method. Bravis would make the following journal entry at December 31. 2011:

COGS 1,200 Allowance to Reduce Inventory to Market Value 1,200

The financial statement effects of the aggregate approach, as compared to the year one benchmark, are shown in Exhibit 2.

EXHIBIT 2 Financial Statement Effects of the Aggregate Approach (Compared to the Year One Benchmark) Aggregate Approach Year One Benchmark Cost of $66,400 ($65,200 Goods Sold + $1,200) $65,200 Loss from $ 0 $2,000 Inventory Write-Down Inventory (net) $13,600 ($14,800 at Dec. 31, 2011 - $1,200) $12,800 Comparison of methods. As compared to the individual-item approach, the aggregate approach results in an $800 higher net income (disregarding taxes) and an $800 higher value for inventory. This outcome occurs because the individual-item approach does not permit the increase in the market value of Item B to offset any of the decline in the market value of Item A. Inventory valuation under the aggregate approach must always be equal to or greater than the value under the individual-item approach. The individual-item approach is the most conservative method, because it results in the lowest possible value for inventory. Example: Year Two Assume that the next reporting period is one year later (December 31, 2012). Suppose that all inventory purchases made in 2012 occur at December 31, 2011, prices ($16 for Item A and $7 for Item B ); however, at December 31, 2012, the DMV of Item A is $15 and the DMV of Item B is $8.

Individual-item approach. Assume purchases and sales during 2012, as well as the amounts for COGS and ending inventory (if no allowance account is used), are indicated in Exhibit 3. Because the inventory detail was adjusted at December 31, 2011, the original $20 unit cost for the 500 units of Item A in beginning inventory was replaced by the $16 DMV; as a result, when those units are sold (and under FIFO, all are considered sold during 2012), the correct unit cast of $16 is charged to COGS. An adjusting entry must be made (and the inventory detail adjusted) to write down the 700 units of Item A in ending inventory from the recorded unit value of $16 to the DMV of $15, as shown below:

Loss from Write-Down of 700 Inventory to Market Value Inventory 700 EXHIBIT 3 Information for Patchasos, Sales, and Cess 12012i Item Beg. Units Units Units on 2012 COGS Totals (per Units Purchased Sold hand at * detail) at Dec. 31, Dec. 31, 2012 2012 [dagger] A 500 2,800 2,600 700 $41,600 $11,200 B 800 5,500 6,000 300 $41,200 $2,100 Total $82,800 $13,300 Item Total DMV Individual at Dec 31, LCM at Dec. 2012 31, 2012 [double dagger] A $10,500 $10,500 B $2,400 $2,100 Total $12,900 $12,600 * A: 2,600 at $16 = $41,600 [dagger] A: 700 at $16 = $11,200 [double dagger] A: 700 at $15 = $10,500 B: 800 at $6 + 5,200 at $7 = $41,200 B: 300 at $7 = $2,100 B: 300 at $8 = $2,400

For reference purposes, the results (summarized below) of the individual-item approach, without the use of an allowance account, are referred to as the "year two benchmark":

Cost of Goods Sold $82,800 Loss from Write-Down of $700 Inventory to Market Value Inventory at Dec. 31, 2012 $12,600 What if the individual-item approach is used in conjunction with an allowance account? Because the inventory detail at December 31, 2011, was not adjusted for the write-down of Item A, COGS will be debited for the original cost of $20 per unit when the inventory is sold. Thus, if the allowance method is used, 2012 COGS (before adjustment) will be $84,800, which is $2,000 (500 units multiplied by $4 per unit) more than the year two benchmark.

Using the individual-item approach, the desired credit balance in the allowance account at December 31, 2012, is $700 (the $13,300 in the inventory detail minus the $12,600 proper balance under individual LCM). Because the current balance (carried over from December 31, 2011) is a $2,000 credit, a $1,300 debit to the allowance account is indicated, resulting in the following entry:

Allowance to Reduce Invent 1,300 Market Value ($2,000-$700) COGS 1,300 Although this entry generates the correct ending balance in the allowance account and the desired net value for inventory ($12,600), it results in COGS of $83,500 ($84,800 - $1,300), which is $700 higher than the year two benchmark. As shown for year one, any loss from writing down inventory is included with COGS when an allowance account is used. The main effect that the decision to use or not use an allowance account has on the financial statements, assuming that the individual item approach is used, relates to the presentation of the income statement. (Another potential effect is discussed later.) Net income will be the same under either technique. If the amounts involved are small enough that proper classification on the income statement is not a concern, this issue is probably inconsequential, and the allowance method can be safely used by simply adjusting the allowance to the desired balance at each reporting date (with the other side of the entry to COGS). But if the amounts are significant, it would be preferable to properly segregate inventory write-downs from COGS on the income statement. Although it is more costly to do so, adjusting the inventory detail for any write-downs (i.e., not using an allowance account) is the surest way to accomplish this objective.

Aggregate approach. The market value of the entire inventory ($12,900) is less than cost ($13,300), indicating a required credit balance of $400 in the allowance. Because the current balance (carried over from December 31, 2011) is a $1,200 credit, an $800 debit entry to the allowance account is required, as follows:

Allowance to Reduce Inventory 800 to Market Value ($1,200-$400) COGS 800

The financial statement effects of the aggregate approach, compared to the year two benchmark, are summarized in Exhibit 4.

EXHIBIT 4 Financial Statement Effects of the Aggregate Approach (Compared to the Year Two Benchmark) Aggregate Approach Year Two Benchmark Cost of Goods $84,000 ($84,800 - $82,800 Sold $800) Loss from $0 $700 Inventory Write-Down Inventory (net) $12,900 ($13,300 - $12,600 at Dec. 31,2012 $400) Comparison of methods. Compared to the individual-item approach, the aggregate approach results in a $500 lower net income (disregarding taxes) and a $300 higher value for inventory. This occurs because the $800 difference (between the two approaches) in inventory value at December 31, 2011, has declined to only $300 at December 31, 2012; the $500 decrease in the difference generates an extra $500 charge under the aggregate approach, as compared to the individual-item approach. This example demonstrates that, although the individual-item approach produces the most conservative inventory valuation at a point in time, net income for a given year under the aggregate approach might be higher or lower than net income under the individual-item approach. Considering an Additional Issue

In the year two example, it was assumed that all of the units of hem A that were on hand at December 31, 2011, were sold during 2012. But what if some of those units remain unsold at the next reporting date? Using the same data for year one, continue to assume that all inventory purchases made in 2012 occur at December 31, 2011, prices ($16 for Item A and $7 for Item B); however, assume that the DMV at December 31, 2012, of Item A is $17 (instead of the $15 used previously for year two) and the DMV of Item B is $8. For this example, it is assumed that Bravis uses the individual-item approach, in conjunction with an allowance account. Additional information for year two, under this modified example, is shown in Exhibit 5.

EXHIBIT 5 Additional Information for Year Two Item Beg. Units Units Units on 2012 COGS Totals (per Units Purchased Sold hand at * detail) at Dec. 31, Dec. 31, 2012 2012 [dagger] A 500 200 300 400 $ 6,000 200 at $20=$4,000 200 at $16=$3,200 B 800 5,500 6,000 300 $41,200 $2,100 Total $47,200 $9,300 Item Total DMV at Individual Dec. 31, 2012 LCM at Dec. [double 31, 2012 dagger] A 200 at $3,400 $17=$3,400 200 at $3,200 $17=$3,400 B $2,400 $2,100 Total $9,200 $8,700 * A: 300 at $20 = $ 6,000 B: 800 at $6 + 5,200 at $7 = $41,200 [dagger] B: 300 at $7 = $2,100 [double dagger] B: 300 at $8 = $2,400 This example focuses on the 200 units of Item A that were on hand at December 31, 2011, and remain on hand at December 31, 2012. Because the detail was not adjusted, the LCM analysis will be based on the $20 unit value shown in the detail; only the most perceptive person would recognize that the cost basis of these items should be $16, especially if there are numerous inventory items. Although it will appear that these 200 items are being written down in value (from $20 to $17 per unit), they are actually being increased in value from the correct cost basis of $16 to the December 31, 2012, DMV of $17 per unit. In this situation, the use of an allowance account will likely trigger the recognition of a $200 recovery of a previous write-down, which is prohibited by U.S. GAAP.

The LCM analysis, as performed, indicates a required credit balance of $600 ($9,300 - $8,700) in the allowance. Because the current balance (carried over from December 31, 2011) is a $2,000 credit, the following entry will be made:

Allowance to Reduce Inventory to 1,400 Market Value ($2,000-$600) COGS 1,400 In fact, the only entry that should have been made to the allowance arises from the 300 units of Item A in beginning inventory that were sold in 2012. Because the items have been sold, the $1,200 (300 x $4) that was in the allowance related to those items should be removed. Thus, the debit entry to the allowance at December 31, 2012, should have been $1,200, not $1,400, and the December 31, 2012, balance in the allowance should be an $800 credit. As a result of this incorrect entry, the net value shown for inventory will be $8,700, instead of the correct value of $8,500, and 2012 net income (disregarding taxes) will be overstated by $200. Although not demonstrated here, the same outcome can occur if the aggregate approach is used. The key factor enabling the recovery of a previous write-down is that the inventory detail is not adjusted to reflect write-downs, which is associated with the use of an allowance account. Practical Considerations The basic premise of LCM accounting is rather simple: a decline in the utility of inventory should be expensed in the period of the decline (rather than waiting until when the inventory is sold), and the value of the inventory should be written down to its replacement cost. In most cases, valuation of inventory at an amount in excess of cost is prohibited under U.S. GAAP. In addition, if a write-down of inventory is required, that value becomes the new cost basis for the inventory, and recognition of any recovery in value is forbidden. From a practical standpoint, designing procedures to comply with these requirements is not as straightforward as it might seem. Companies must decide if the inventory detail should be adjusted for write-downs, or if an allowance account (with no adjustment to the detail) should be used. Adjusting the detail is time-consuming and tedious, but doing so will enable the company to segregate the amount of any write-down loss from COGS--a desirable result. Furthermore, if an allowance account is used, then extreme care must be taken to ensure that recoveries of previous write-downs are not inadvertently recognized. Under specified. conditions, U.S. (MAY permits the LCM rule to be applied to an aggregate level of inventory, rather than to each individual inventory item. When the LCM analysis is applied to the entire inventory (or to major categories), it implicitly permits the write-up of inventory items to the extent that other inventory items are written down, a notable exception to the core LCM rules. For this reason, companies should take care to use the aggregate approach only when it is sanctioned by U.S. GAAP, lest they unintentionally and inappropriately violate the general provision that prohibits valuing inventory above cost. To ensure strict compliance with U.S. GAAP, LCM should be applied using the individual item approach, with the inventory detail adjusted for any write-downs, These procedures will ensure that inventory is valued at the most conservative amount and that no recoveries of previous write-downs are recognized. But in light of the materiality of the amounts involved, CPAs should carefully consider the costs and benefits of the different methods when determining which method is best for any particular company.

Bruce Wampler, DBA, CPA, is an associate professor and Travis Holt, PhD, CPA, is a UC Foundation assistant professor, both in the college of business at the University of Tennessee at Chattanooga