Update to Consolidation Guidelines Exhibit D – VIE Disclosures Both public and nonpublic reporting entities must disclose the following information depending on whether the entity is the primary beneficiary. Primary Beneficiary  Methodology for determining the primary beneficiary, including significant judgments and assumptions  If the consolidation conclusion has changed in the period, the primary factors that caused the change and effect on financial statements  Whether the reporting entity has provided financial or other support to the VIE that it previously was not contractually obligated to provide  Qualitative and quantitative information about involvement with the VIE  Carrying amounts and classifications of the consolidated VIE’s assets and liabilities  Lack of recourse if creditors or beneficial interest holders of a consolidated VIE have no recourse to the general credit of the primary beneficiary  Terms of arrangements that could require primary beneficiary to provide financial support to the VIE  Amount of gain or loss on initial consolidation of the VIE if the primary beneficiary of a VIE is not a business A VIE may issue voting equity interests, and the entity that holds a majority voting interest also may be the primary beneficiary of the VIE. In this case, if the VIE’s assets can be used for purposes other than the settlement of the VIE’s obligations, the aforementioned disclosures are not required. Holder of a Significant Variable Interest in a VIE A reporting entity that holds a significant variable interest in a VIE but is not the primary beneficiary shall disclose all the following:  Methodology for determining the primary beneficiary, including significant judgments and assumptions  If the consolidation conclusion has changed in the period, the primary factors that caused the change and effect on financial statements  Whether the reporting entity has provided financial or other support to the VIE that it previously was not contractually obligated to provide  Qualitative and quantitative information about involvement with the VIE  Carrying amounts and classifications of the assets and liabilities in the entity’s balance sheet that relate to the entity’s variable interest in the VIE  The reporting entity’s maximum exposure to loss as a result of its involvement with the entity, including how the maximum exposure is determined and the significant sources of the reporting entity’s exposure to the VIE; if maximum exposure cannot be quantified, that fact must be disclosed  A tabular comparison of the carrying amounts of the assets and liabilities with the maximum exposure to loss, along with qualitative and quantitative information on the reason for the differences  Information about liquidity arrangements, guarantees or other third-party commitments that may affect the fair value or risk of the reporting entity’s variable interest in the VIE  If power is determined to be shared, significant factors considered and judgments made 18 .