Lessons Learned From SEC Comment Letters on The New Revenue Standard

The new revenue standard is effective for all public entities for annual periods beginning January 1, 2018 for calendar year-end public entities. The SEC’s Division of Corporation Finance has selectively reviewed filings to monitor and enhance compliance with applicable disclosure and accounting requirements of the new standard. FEI reviewed revenue-related comment letter correspondence between the SEC and filers, and found the following trends:
  • Early adopters have been asked to clarify considerations made for operationalizing different aspects of the standard
  • The SEC began requesting more robust SAB 74 disclosures for periods ending December 31, 2016
  • Several companies have disclosed incorrect effective dates for ASC 606 in their SAB 74 disclosures

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