FASB memos shed light on private company revenue recognition issues

Two FASB staff memos issued in June provide insight to private company financial statement preparers on how to overcome implementation challenges that some have encountered with the new revenue recognition standard.

The memos address concerns raised in a letter sent to FASB in January by the AICPA Technical Issues Committee (TIC). The memos do not purport to represent the views of any individual members of FASB or the staff, nor do the memos claim to establish acceptable application of GAAP.

Nonetheless, the memos provide insight into the thinking of FASB’s staff related to some issues raised by TIC.

The first memo, dated June 15, explains that many public companies have avoided the need to estimate out-of-pocket reimbursements using existing guidance in the revenue recognition standard. The principal-versus-agent analysis narrows the population of contracts affected by the out-of-pocket issue, according to the memo, as several Private Company Council members said during an April meeting that “passthrough expenses” should not have to be estimated and should not have any effect on profit margins.

FASB staff outreach shows that when a company is required to estimate the reimbursement, most companies retain current practice by asserting that the change is immaterial. When the reimbursements are material, the memo says companies have handled implementation in one of three ways:

• Developing estimates at the portfolio level;
• Implementing thresholds for the accounting (that is, only estimating reimbursements over a certain amount); or
• Implementing new tracking systems.

The second memo, dated June 19, states that in some cases it may not be clear whether a contract exists, so additional work may be required (which may or may not require legal assistance) to determine whether enforceable rights and obligations to payment exist. But the memo states that such additional work would be required in a minority of contracts, and that the new rules are “not dissimilar from today’s requirements.”

With regard to short-cycle manufacturing, FASB’s staff understands that preparers have had questions about how to handle contracts when the entity creates a good with no alternative use and the contract with its customer does not specify by its written terms the entity’s right to payment upon contract termination. The memo states that FASB’s staff believes it’s reasonable to interpret from the revenue recognition guidance that when a contract’s written terms do not specify the entity’s right to payment upon contract termination, an enforceable right to payment is presumed not to exist.