Are You Ready for the Proposed Changes to Accounting for ... - PwC
Are You Ready for the Proposed Changes to Accounting for ... - PwC
Are You Ready for the Proposed Changes to Accounting for ... - PwC
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Issue Alert November 16, 2010<br />
<strong>Are</strong> <strong>You</strong> <strong>Ready</strong> <strong>for</strong> <strong>the</strong> <strong>Proposed</strong><br />
<strong>Changes</strong> <strong>to</strong> <strong>Accounting</strong> <strong>for</strong> Leases<br />
By Jim Kaiser, Denise Cutrone and Lyn Fifer,<br />
PricewaterhouseCoopers, LLP<br />
On August 17, 2010, <strong>the</strong> Financial <strong>Accounting</strong> Standards Board<br />
(FASB) and <strong>the</strong> International <strong>Accounting</strong> Standards Board (IASB)<br />
proposed a new approach <strong>to</strong> lease accounting that would<br />
significantly change <strong>the</strong> way entities account <strong>for</strong> leases. Their<br />
exposure drafts, Leases, would result in a converged standard that<br />
aims <strong>to</strong> address <strong>the</strong> perceived weaknesses of existing standards.<br />
The key objective is <strong>to</strong> ensure assets and liabilities arising from lease<br />
contracts are recognized in <strong>the</strong> balance sheet. The exposure draft<br />
does not propose a specific effective date, but it is anticipated that<br />
<strong>the</strong> final standard will not be effective be<strong>for</strong>e 2013 and would require<br />
comparative periods.<br />
Recently, Credit Suisse published an article in August 2010 entitled,<br />
Leases Landing on Balance Sheet, where <strong>the</strong>y estimated that $549<br />
billion of off-balance sheet lease liabilities (i.e., operating leases) will<br />
be recognized on <strong>the</strong> balance sheets of <strong>the</strong> S&P 500 companies<br />
(Suisse, 2010, p. 1).<br />
Given <strong>the</strong> potential impact of <strong>the</strong> proposed changes on accounting,<br />
operations and IT systems, companies should begin assessing <strong>the</strong><br />
implications of <strong>the</strong> proposal on existing contracts, technology and<br />
processes. This Issue Alert summarizes <strong>the</strong> key provisions of <strong>the</strong><br />
Leases exposure draft and includes a self-assessment questionnaire<br />
developed by PricewaterhouseCoopers LLP <strong>to</strong> help companies<br />
understand <strong>the</strong> potential impact of <strong>the</strong> Leases exposure draft.<br />
What should companies be doing now<br />
Inven<strong>to</strong>ry existing leases and per<strong>for</strong>m an assessment <strong>to</strong><br />
determine <strong>the</strong> impacts of <strong>the</strong> proposed standard <strong>to</strong> your<br />
company. (See attached questionnaire)<br />
Evaluate existing IT systems and hold discussions with ERP<br />
providers <strong>to</strong> assess <strong>the</strong> system’s current capabilities, and<br />
whe<strong>the</strong>r upgrades are both necessary and available.<br />
Consider <strong>the</strong> impacts of <strong>the</strong> new rules upon major company<br />
initiatives, such as systems and compensation plans.<br />
Begin <strong>to</strong> assess what data will need <strong>to</strong> be collected and<br />
analyzed prior <strong>to</strong> adopting <strong>the</strong> standard, <strong>to</strong> allow <strong>for</strong> a<br />
comparative presentation.<br />
Consider <strong>the</strong> impacts on “lease versus buy” strategies.<br />
Establish a training and communication plan with employees<br />
and key stakeholders.<br />
Consider sending a comment letter <strong>to</strong> <strong>the</strong> FASB and IASB <strong>to</strong><br />
express your views prior <strong>to</strong> <strong>the</strong> issuance of <strong>the</strong> standard.<br />
Financial Executives Research Foundation | 1
The Key Provisions<br />
Lessee <strong>Accounting</strong><br />
The proposal effectively eliminates off-balance sheet or operating lease accounting <strong>for</strong> most<br />
leases. All assets currently leased under operating leases would be brought on<strong>to</strong> <strong>the</strong><br />
balance sheet, removing <strong>the</strong> distinction between capital and operating leases. Lessees<br />
would be required <strong>to</strong> discount <strong>the</strong> lease payments using its incremental borrowing rate at <strong>the</strong><br />
transition date (i.e., January 1, 2011). O<strong>the</strong>r significant impacts include:<br />
A right-of-use asset (representing <strong>the</strong> right <strong>to</strong> use <strong>the</strong> leased item <strong>for</strong> <strong>the</strong> lease term)<br />
and an obligation (representing <strong>the</strong> obligation <strong>to</strong> pay rentals) would be recognized and<br />
carried at amortized cost, based on <strong>the</strong> present value of payments over <strong>the</strong> term of <strong>the</strong><br />
lease.<br />
The lease term would include optional renewal periods that are "more likely than not" <strong>to</strong><br />
be exercised.<br />
Lease payments used <strong>to</strong> measure <strong>the</strong> initial value of <strong>the</strong> asset and liability would include:<br />
contingent amounts, such as rents based on a percentage of sales or rent increases<br />
linked <strong>to</strong> variables such as <strong>the</strong> Consumer Price Index (CPI).<br />
Lease renewal and contingent rents would need <strong>to</strong> be continually reassessed, and <strong>the</strong><br />
related estimates adjusted as facts and circumstances change.<br />
The income statement geography and <strong>the</strong> recognition pattern <strong>for</strong> lease expenses would<br />
change. Straight-line rent expense would be replaced by amortization and interest<br />
expense and would result in an acceleration of expense recognition, as interest on <strong>the</strong><br />
obligation would be greater in <strong>the</strong> earlier years.<br />
Lessor <strong>Accounting</strong><br />
After much debate, <strong>the</strong> FASB and IASB are proposing a dual model <strong>for</strong> lessor accounting.<br />
Depending on <strong>the</strong> economic characteristics of <strong>the</strong> lease, a lessor would apply ei<strong>the</strong>r a<br />
per<strong>for</strong>mance obligation approach or a de-recognition approach:<br />
The per<strong>for</strong>mance obligation approach would be used <strong>for</strong> leases where <strong>the</strong> lessor<br />
retains exposure <strong>to</strong> significant risks or benefits associated with <strong>the</strong> leased asset,<br />
ei<strong>the</strong>r during <strong>the</strong> term of <strong>the</strong> contract or subsequent <strong>to</strong> <strong>the</strong> term of <strong>the</strong> contract.<br />
Under this approach, <strong>the</strong> lessor would recognize a lease receivable, representing <strong>the</strong><br />
right <strong>to</strong> receive rental payments from <strong>the</strong> lessee, with a corresponding per<strong>for</strong>mance<br />
obligation, representing <strong>the</strong> obligation <strong>to</strong> permit <strong>the</strong> lessee <strong>to</strong> use <strong>the</strong> leased asset.<br />
Lessors would measure <strong>the</strong> lease receivable and per<strong>for</strong>mance obligation using <strong>the</strong><br />
rate <strong>the</strong> lessor is charging <strong>to</strong> <strong>the</strong> lessee (from <strong>the</strong> lease inception date) as <strong>the</strong><br />
discount rate.<br />
The de-recognition approach would be followed <strong>for</strong> all o<strong>the</strong>r leases. The lessor<br />
would recognize a receivable representing <strong>the</strong> right <strong>to</strong> receive rental payments from<br />
<strong>the</strong> lessee and record revenue. In addition, <strong>the</strong> carrying value of <strong>the</strong> leased asset<br />
that is considered <strong>to</strong> have been transferred <strong>to</strong> <strong>the</strong> lessee would be derecognized and<br />
recorded as cost of sales.<br />
Under ei<strong>the</strong>r approach, lessors would need <strong>to</strong> estimate <strong>the</strong> lease term and contingent<br />
payments and adjust <strong>the</strong>se estimates as facts and circumstances change. The lessor would<br />
also measure <strong>the</strong> lease receivable using <strong>the</strong> rate <strong>the</strong> lessor is charging <strong>to</strong> <strong>the</strong> lessee (from<br />
<strong>the</strong> lease inception date) as <strong>the</strong> discount rate.<br />
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Presentation and Disclosures<br />
Due <strong>to</strong> <strong>the</strong> significantly expanded use of estimates and judgments in <strong>the</strong> proposed lease<br />
standard, disclosure requirements will go well beyond those required under current leasing<br />
standards. Quantitative and qualitative financial in<strong>for</strong>mation that identifies and explains <strong>the</strong><br />
amounts recognized in financial statements arising from lease contracts and a description of<br />
how leases may affect <strong>the</strong> amount, timing, and uncertainty of <strong>the</strong> entity’s future cash flows<br />
would be required.<br />
Specific disclosures would also be required and include a description of <strong>the</strong> nature of an<br />
entity's leasing arrangements, <strong>the</strong> existence and terms of optional renewal periods and<br />
contingent rentals, and in<strong>for</strong>mation about assumptions and judgments. In addition, any<br />
restrictions imposed by lease arrangements, such as dividends, additional debt, and fur<strong>the</strong>r<br />
leasing should also be disclosed. The following disclosures would also be required:<br />
In<strong>for</strong>mation about <strong>the</strong> principal terms of any lease that has not yet commenced if <strong>the</strong><br />
lease creates significant rights and obligations.<br />
A reconciliation between <strong>the</strong> opening and closing balances of right-of-use assets and<br />
obligations <strong>to</strong> pay rentals, disaggregated by class of underlying asset.<br />
A narrative disclosure of significant assumptions and judgments relating <strong>to</strong> renewal<br />
options, contingent cash flows, and <strong>the</strong> discount rate used.<br />
A maturity analysis of <strong>the</strong> gross obligation <strong>to</strong> pay rentals showing (a) undiscounted cash<br />
flows on an annual basis <strong>for</strong> <strong>the</strong> first five years and a <strong>to</strong>tal of <strong>the</strong> amounts <strong>for</strong> <strong>the</strong><br />
remaining years and (b) amounts attributable <strong>to</strong> <strong>the</strong> minimum amounts specified in <strong>the</strong><br />
lease and <strong>the</strong> amounts recognized in <strong>the</strong> balance sheet.<br />
Additional disclosures would apply if (a) <strong>the</strong> simplified option <strong>for</strong> short-term leases is<br />
elected, (b) significant subleases exist, or (c) <strong>the</strong>re is a sale-leaseback transaction.<br />
Financial Executives Research Foundation | 3
Impacts <strong>to</strong> Existing IT Infrastructure<br />
The system implications will affect lessees and lessors differently. As such, a separate<br />
analysis of <strong>the</strong> system impacts <strong>for</strong> parties on both sides of <strong>the</strong> lease transaction is<br />
necessary.<br />
It is also worth recognizing that companies may have a variety of systems in place <strong>to</strong><br />
manage in<strong>for</strong>mation. With so many systems, it is difficult <strong>to</strong> generalize <strong>the</strong> impacts.<br />
There<strong>for</strong>e <strong>the</strong> concepts discussed below are intended as thought provoking examples.<br />
As a basic framework, <strong>the</strong>re are five layers of systems that may be impacted, and will need<br />
<strong>to</strong> carry different parts of <strong>the</strong> load. The five layers are:<br />
1. Consolidations / Reporting<br />
2. Data Warehouse<br />
3. General Ledger<br />
4. Subsystem / Subledger<br />
5. Governance, Risk and Compliance<br />
For lessee accounting, <strong>the</strong> following should be considered:<br />
Consolidation / Reporting:<br />
The immediate issue will be <strong>the</strong> need <strong>to</strong> support multiple reporting <strong>for</strong>mats during <strong>the</strong><br />
adoption of <strong>the</strong> converged standard. Depending on how tax and o<strong>the</strong>r regula<strong>to</strong>ry reporting<br />
are supported, <strong>the</strong>re may be a longer term need <strong>to</strong> support multiple reporting <strong>for</strong>mats.<br />
These systems will be <strong>the</strong> likely source <strong>for</strong> additional disclosures required by <strong>the</strong> new<br />
standard. Additional disclosures will likely include:<br />
• Roll<strong>for</strong>ward in<strong>for</strong>mation such as <strong>the</strong> opening and closing balance of <strong>the</strong> right-of use<br />
asset and obligation, lease receipts and payments, lease income, interest income,<br />
and depreciation expense, disaggregated by class of underlying asset.<br />
• A narrative disclosure of significant assumptions and judgments relating <strong>to</strong> renewal<br />
options, contingent cash flows, and <strong>the</strong> discount rate used.<br />
• A maturity analysis of <strong>the</strong> gross obligation <strong>to</strong> pay rentals showing (a) undiscounted<br />
cash flows on an annual basis <strong>for</strong> <strong>the</strong> first five years and a <strong>to</strong>tal of <strong>the</strong> amounts <strong>for</strong><br />
<strong>the</strong> remaining years and (b) amounts attributable <strong>to</strong> <strong>the</strong> minimum amounts specified<br />
in <strong>the</strong> lease and <strong>the</strong> amounts recognized in <strong>the</strong> balance sheet.<br />
These systems are also often used as a basis <strong>for</strong> budgeting and planning, and so <strong>the</strong> impact<br />
<strong>to</strong> expense versus capital budgets should be considered.<br />
Data Warehouse<br />
The data warehouse will need <strong>to</strong> be evaluated <strong>to</strong> see how <strong>the</strong> change in transactional<br />
treatment will impact <strong>the</strong> usability of <strong>the</strong> data. The data warehouse is often used as <strong>the</strong><br />
source <strong>for</strong> developing financial analysis and ratios. The underlying data may impact how<br />
<strong>the</strong>se are calculated and how comparative data is produced.<br />
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General Ledger<br />
For <strong>the</strong> majority of companies with an ERP solution in place, <strong>the</strong> general ledger (GL) is<br />
currently being used <strong>to</strong> capture entries sourced in a subledger / subsystem. The impact <strong>to</strong><br />
<strong>the</strong> general ledger will depend on how much can be handled by <strong>the</strong> transaction system.<br />
There will be different values posted in<strong>to</strong> <strong>the</strong> GL, and depending on <strong>the</strong> approach taken, this<br />
could require additional GL accounts or ledgers. The integration between <strong>the</strong> GL and <strong>the</strong><br />
data warehouse and consolidation / reporting systems will also need <strong>to</strong> be considered.<br />
Subsystem / Subledger<br />
The three subsystems / subledgers where impact might be felt include <strong>the</strong> asset system,<br />
purchasing and <strong>the</strong> contract management system. The asset system will be brought in<strong>to</strong><br />
play <strong>for</strong> many more assets than under existing US GAAP / IFRS, and those asset records<br />
will need <strong>to</strong> contain amortization expenses of <strong>the</strong> asset and <strong>the</strong> accrued liability. The righ<strong>to</strong>f-use<br />
assets will also need <strong>to</strong> be distinguishable from o<strong>the</strong>r purchased assets <strong>for</strong> reporting<br />
purposes, and <strong>the</strong> need <strong>to</strong> annually review and adjust <strong>the</strong> assets based on a change in<br />
estimates also needs <strong>to</strong> be accommodated.<br />
The purchasing application will also be impacted as <strong>the</strong> financial impact of what is being<br />
acquired has changed. The purchasing process will need <strong>to</strong> be able <strong>to</strong> capture not just <strong>the</strong><br />
lease rental amounts, but also <strong>the</strong> full cost <strong>to</strong> <strong>the</strong> business, and any future renewal options.<br />
The approval process against budgets will also need <strong>to</strong> be adjusted <strong>to</strong> fit <strong>the</strong> new accounting<br />
treatment.<br />
If contract details are maintained in a separate system, this system will need <strong>to</strong> capture<br />
additional in<strong>for</strong>mation regarding <strong>the</strong> lease obligations and right-of-use assets.<br />
Governance Risk and Compliance<br />
With additional and amended business processes around <strong>the</strong>se assets, <strong>the</strong> process<br />
documentation will need <strong>to</strong> be adapted and <strong>the</strong> appropriate controls will need <strong>to</strong> be<br />
incorporated in<strong>to</strong> <strong>the</strong> processes.<br />
For lessor accounting, <strong>the</strong> following should be considered:<br />
For <strong>the</strong> majority of areas, <strong>the</strong> items <strong>to</strong> be considered will be similar, although <strong>the</strong> source<br />
transactions will be different. The area where <strong>the</strong>re is an additional element <strong>to</strong> consider is in<br />
<strong>the</strong> subledger / subsystem layer. Here <strong>the</strong> system used <strong>to</strong> manage assets and equipment<br />
that is leased out will potentially need <strong>to</strong> handle <strong>the</strong> de-recognition approach as well as <strong>the</strong><br />
per<strong>for</strong>mance obligation approach, and will also need <strong>to</strong> adjust <strong>for</strong> contingent and o<strong>the</strong>r<br />
estimates as circumstances change. Depending on <strong>the</strong> complexity of <strong>the</strong> lessor operations,<br />
this may be managed through standard sales / revenue system or <strong>for</strong> more complex<br />
situations where a lease administration/property management system is used. These<br />
systems should also be evaluated and companies will need <strong>to</strong> assess whe<strong>the</strong>r <strong>the</strong><br />
necessary data is available in a usable <strong>for</strong>mat in <strong>the</strong>ir current lease administration systems.<br />
Additional data will need <strong>to</strong> be captured under <strong>the</strong> new standard that may not have been<br />
critical be<strong>for</strong>e. That data includes estimates of contingent rents, option renewal terms,<br />
inputs <strong>to</strong> calculate lease terms in accordance with <strong>the</strong> new standard, and a review of<br />
contracts <strong>to</strong> evaluate whe<strong>the</strong>r lease payments include service costs that should be<br />
bifurcated from payments <strong>for</strong> <strong>the</strong> leased asset. Only <strong>the</strong> lease payment should be used in<br />
calculating <strong>the</strong> lease receivable.<br />
Financial Executives Research Foundation | 5
Initial Lease Discussion Questionnaire<br />
One way that companies can get started is <strong>to</strong> assess <strong>the</strong> potential impact of <strong>the</strong>se<br />
accounting changes on financial reporting systems and financial statements. A good first<br />
step is <strong>to</strong> try <strong>to</strong> understand <strong>the</strong> scale of <strong>the</strong> potential ef<strong>for</strong>t at your organization, including<br />
treasury, legal and real estate (if applicable). Below are a few questions that can help<br />
companies per<strong>for</strong>m a self assessment <strong>to</strong> try and understand <strong>the</strong> scale of <strong>the</strong> potential ef<strong>for</strong>t.<br />
1. How many leases do you have (Include transactions that are not leases in legal<br />
<strong>for</strong>m, but are accounted <strong>for</strong> as such, such as embedded leases.)<br />
2. What are <strong>the</strong> lease terms of your lease agreements<br />
3. What types of "large ticket" assets do you lease (Include corporate real estate, real<br />
estate used in operations/production, land leases, operating or manufacturing<br />
equipment, etc.)<br />
4. Do you have a large volume of "smaller dollar" leases that individually would not be<br />
material, but that in aggregate could be significant, such as fleet vehicles, office or<br />
inven<strong>to</strong>ry related equipment and software leases<br />
5. "Complex" leases under <strong>the</strong> standard will involve more assumptions and require<br />
significantly more on-going accounting than <strong>to</strong>day's standards. Do your leases<br />
commonly include any of <strong>the</strong> following:<br />
Renewal options (market or fixed/ variable)<br />
Contingent rent (market or fixed/ variable)<br />
Purchase options (market or fixed/ variable)<br />
Lessee participation in residual value, including Residual Value Guarantees,<br />
remarketing rights/ obligations, TRAC leases.<br />
6. Where does <strong>the</strong> in<strong>for</strong>mation on your leases reside For example, are <strong>the</strong> lease<br />
agreements located in a central or de-centralized location, regional headquarters, or<br />
maintained on a country-by-country basis<br />
7. What systems do you use <strong>to</strong> manage your leases How do you currently capture<br />
lease specific in<strong>for</strong>mation, such as execu<strong>to</strong>ry costs, contingent rents, renewal terms,<br />
tenant improvement allowance, options <strong>to</strong> expand or terminate early Some<br />
common examples include an integrated workspace management system, Access<br />
database, Excel worksheets, or SAP/Oracle.<br />
8. Have you had discussions with your ERP/ Service provider about <strong>the</strong>ir ability <strong>to</strong><br />
make system changes <strong>to</strong> meet <strong>the</strong> new standard<br />
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Conclusion<br />
In summary, <strong>the</strong> proposed leasing model will have far reaching implications <strong>for</strong> companies.<br />
It will not only affect IT systems and controls, but also <strong>the</strong> in<strong>for</strong>mation needs, financial<br />
metrics and lease-versus-buy decisions. As such, companies may want <strong>to</strong> begin thinking<br />
about <strong>the</strong> potential business implications now, well be<strong>for</strong>e a final standard is issued.<br />
If you would like fur<strong>the</strong>r in<strong>for</strong>mation on <strong>the</strong> proposed lease accounting model or assistance<br />
in determining how it might affect your business, contact in<strong>for</strong>mation <strong>for</strong> <strong>the</strong> <strong>PwC</strong> authors is<br />
provided below.<br />
For additional insight regarding <strong>the</strong> business impacts of convergence between U.S. GAAP<br />
and IFRS, please visit <strong>PwC</strong>'s dedicated convergence website at<br />
www.pwc.com/usgaapconvergence.<br />
About <strong>the</strong> Authors<br />
Jim Kaiser is <strong>PwC</strong>'s US GAAP convergence & IFRS leader. As such, he leads a<br />
multidisciplinary team in developing <strong>the</strong> firm's strategy <strong>to</strong> help clients through <strong>the</strong> complex<br />
business issues related <strong>to</strong> near-term convergence and ultimate conversion <strong>to</strong> IFRS in <strong>the</strong><br />
US. Jim has over 30 years experience serving major international clients in a wide range of<br />
industries. He has worked extensively with his clients in mergers and acquisitions including<br />
due diligence, merger integration and public offerings services, and has led his clients in reengineering<br />
<strong>the</strong>ir audit and closing processes. Jim developed <strong>PwC</strong>'s industry program <strong>for</strong><br />
<strong>the</strong> chemicals, <strong>for</strong>est products, metals, and diversified manufacturing industries. He serves<br />
on a number of boards as well as <strong>the</strong> American and Pennsylvania Institutes of Certified<br />
Public Accountants. James.kaiser@us.pwc.com<br />
Denise Cutrone is a partner in <strong>PwC</strong>'s Transaction Services Group in Atlanta servicing<br />
financial services clients nationwide. Denise is fully dedicated <strong>to</strong> providing clients advisory<br />
services in conjunction with complex or new accounting standards and conversions <strong>to</strong><br />
International Financial Reporting Standards ("IFRS") or U.S. GAAP. She is one of our<br />
conversion and embedding experts, who has assisted Global companies with IFRS and U.S.<br />
GAAP conversions <strong>for</strong> <strong>the</strong> past 13 years. Aside from providing technical and conversion<br />
advice, some of her projects have included <strong>the</strong> redesign of financial reporting in order <strong>to</strong><br />
enhance standardization and processes. Denise has also supported clients with various<br />
types of capital market transactions. Denise.cutrone@us.pwc.com<br />
Lyn Fifer is a direc<strong>to</strong>r is in <strong>PwC</strong>'s Transaction Services Group in Atlanta and has nine years<br />
of accounting experience advising clients in multiple industries, including financial services,<br />
industrial products, and <strong>the</strong> au<strong>to</strong>motive industry with respect <strong>to</strong> initial and ongoing U.S.<br />
GAAP, IFRS, and SEC accounting and reporting matters. Lyn has served as an advisor <strong>to</strong> a<br />
number of companies advising on emerging and complex accounting transactions,<br />
specifically as it relates <strong>to</strong> leases, joint venture accounting, consolidation, and securitization<br />
transactions under both U.S. GAAP and IFRS. Lyn has also advised various clients with<br />
debt offerings and IFRS conversion projects. Lyn.fifer@us.pwc.com<br />
Financial Executives Research Foundation | 7
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| Financial Executives Research Foundation
FINANCIAL EXECUTIVES RESEARCH FOUNDATION, INC. would like <strong>to</strong> acknowledge<br />
and thank <strong>the</strong> following companies <strong>for</strong> <strong>the</strong>ir support and generosity:<br />
PLATINUM MAJOR GIFT | $50,000 +<br />
Exxon Mobil Corporation<br />
Microsoft Corporation<br />
GOLD PRESIDENT’S CIRCLE | $10,000 - $14,999<br />
Abbott Labora<strong>to</strong>ries, Inc.<br />
Cisco Systems, Inc.<br />
Dow Chemical Company<br />
General Electric Company<br />
H.S. Grace & Company, Inc.<br />
SILVER PRESIDENT’S CIRCLE | $5,000 - $9,999<br />
ALCOA Foundation<br />
IBM Corporation<br />
Comcast Corporation<br />
Johnson & Johnson<br />
Corning Incorporated<br />
Lockheed Martin Corporation<br />
Credit Suisse<br />
Maple Leaf Foods, Inc.<br />
Cummins Inc.<br />
Medtronic, Inc.<br />
CVS Corporation<br />
Mo<strong>to</strong>rola, Inc.<br />
Dell, Inc.<br />
Pfizer Inc.<br />
Duke Energy Corporation<br />
Procter & Gamble Co.<br />
E. I. du Pont de Nemours & Company Safeway, Inc.<br />
El Paso Corporation<br />
Sony Corporation of America<br />
Eli Lilly and Company<br />
Tenneco<br />
GM Foundation<br />
Tyco International Management Co.<br />
Hallibur<strong>to</strong>n Company<br />
United Technologies Corporation<br />
The Hershey Company<br />
Verizon Communications<br />
Hewlett-Packard Company<br />
Wells Fargo & Company<br />
GOLD CORPORATE LEADERSHIP - $2,500 - $4,999<br />
Cargill, Incorporated<br />
Ea<strong>to</strong>n Corporation<br />
Florida Power & Light Company<br />
Intel Corporation<br />
McCormick & Company, Inc.<br />
Precision Castparts Corp.<br />
PricewaterhouseCoopers<br />
Ray<strong>the</strong>on Company<br />
Select Medical Corp.<br />
Telephone and Data Systems, Inc.<br />
Time-Warner Inc.<br />
Wal-Mart S<strong>to</strong>res, Inc.<br />
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