More ASC 606 Comments from CorpFin

By: George M. Wilson

In this October post we reviewed comment letters that early adopters of the new revenue recognition model in ASC 606 received from CorpFin. The comments focused on issues surrounding the judgments this new principles-based model requires along with the related disclosures.


Another company, CBOE holdings, has joined the group of early adopters and in an August comment letter received these comments:


Financial Statements

  1. Organization and Basis of Presentation, page 6

Please explain to us how you determined that rebates paid to customers in accordance with published fee schedules should not be accounted for as a reduction of the transaction price. Refer to ASC 606 – 10 – 32 – 25 to 32 – 27.

  1. Revenue Recognition, page 8

We note your disclosure that you recognize revenue for certain services over time. Please tell us how you considered the requirements in ASC 606 – 10 – 50 – 13 to 50 – 15 to disclose information about remaining performance obligations or application of optional exemptions.

The same themes, explaining the judgments in applying the new principles and robust disclosure, come through in these comments and can help inform all of us as we implement the new standard.


As always, your thoughts and comments are welcome!


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