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The distinction between accounting treatments that reflect the underlying economic reality of an arrangement versus those that achieve classification through contractual engineering. CADA is built on the substance principle: off-balance-sheet treatment is earned because the deploying foundation genuinely bears economic exposure, not because a contract allocates defined risks across a multi-party structure.
A PPP achieves off-balance-sheet classification through a complex contractual allocation of defined risks while retaining economic exposure on the public balance sheet — form, not substance. A CADA achieves it by actually placing the risk with the deploying foundation — substance, not form.
CADA Section 5