Companies that can’t say at the end of this year how they will be affected by the new revenue recognition standard should consider telling investors when they will have it sorted out.
Wesley Bricker, deputy chief accountant at the Securities and Exchange Commission, said at the annual national conference of the American Institute of Certified Public Accountants that staff will be looking for disclosures that provide useful information to investors who need time to analyze the impact of the standard on companies. “As companies prepare their annual financial statements over the next couple of months, we are looking forward to reviewing more detailed disclosures about the expected effect the new standard will have on those financial statements,” he said. “If that effect is still unknown, then in addition to making a statement to that effect, a registrant may consider advising investors when that assessment is expected to be completed.”
Craig Olinger, deputy chief accountant at the SEC, said the Division of Corporation Finance is hearing questions about various filing rules and their interplay with the new revenue standard, such as management discussion and analysis, the five-year selected financial data disclosures, impact on Regulation SK disclosures and others. The SEC may provide some guidance to answer some of the questions, he said, and is happy to discuss individual questions if they can’t be addressed through broad guidance.
In the meantime, Olinger echoed the interest in 2015 year-end disclosures. Even if companies can’t say specifically how they are affected by the new standard, “you should disclose what you have concluded so far,” he said. “We expect the level of those disclosures to increase between now and adoption.” The staff is not planning a comment-letter campaign based on those disclosures, but “we’re looking forward to what people are doing,” he said.
Companies play a critical role in assuring consistent implementation of the new standard to provide investors with comparable information across companies, said Bricker and his colleague Ashley Wright, a professional accounting fellow. Bricker has spoken before about his concerns over differences in implementation or interpretations as a result of different implementation efforts.
Some companies may be finding as they take a fresh look at their revenue arrangements and accounting policies that they may arrive at different accounting conclusions under the new standard than other companies, even under similar facts and circumstances, said Wright. That’s a problem.
One of the objectives of the new standard, codified in the Accounting Standards Codification under Topic 606, was to improve comparability in the accounting when fact patterns are similar, said Wright. “We are focused on achieving more consistent interpretation and application of the principles as part of the transition to Topic 606,” she said. As differences are identified, “it is important for management to raise those viewpoints” through the Joint Transition Resource Group, AICPA industry task forces, or even through SEC staff.
Consistent application will not only improve comparability out of the gate, but it will spare companies trouble further down the line, Wright said. “It could save companies from incurring additional costs associated with changing after the initial implementation date,” she said.
Bricker pointed out concerns about delays in implementation efforts and urged companies to get busy working on the new standard, elevating the discussion to senior management and the board to assure they have the time and staff to do the job well. “Good practice is to ensure that the agenda for the audit committee, executive management, and auditor incorporates timely, candid discussions about not only the appropriateness of the design and status of management’s detailed implementation plans and impact assessments, but also the sufficiency of resources needed to complete the work timely,” he said.