2/6/2008 Revenue Recognition © E J Walsh, 2006 The Basic Rules .... And what went wrong FUNDAMENTALS OF REVENUE RECOGNITION Revenue Recognition Principles • RT NYC – Sydney - $400 • Property • Buy property 100 units at $100K • Refurbish $50K per unit • Sell at 300K or 18K payable end of each year for 25 years (APR = 3.5%) 1 2/6/2008 Recognition of revenue – US GAAP • SFAC 5 - Recognition & Measurement Revenue must be • • • Realised - when products are exchanged for cash or claims to cash Realisable - when assets received are readily convertible to cash Earned - when the entity has substantially accomplished what it must do to be entitled to the benefits represented by the revenues Guidance – US GAAP • The basic theory for revenue recognition is included in the Statements of Financial Accounting Concepts (SFAC) • SFAC 5 - Recognition & Management • SFAC 6 - Elements of Financial Statements • No overall revenue standard exists, more than 140 pronouncements issued by various standard setters (SEC, FASB, AICPA) Recognition of revenue – US GAAP Examples: a) Recognise at delivery if product is delivered or services rendered b) If sale or cash receipt precedes delivery (e.g. c) d) magazine subscriptions), recognise when produced and delivered If contracted for before production, recognise by a percentage-of-completion method as production takes place if reasonable estimates are available If rights to use assets extend continuously over time (e.g. interest or rent), recognise as time passes 2 2/6/2008 Recognition of revenue – US GAAP Examples: a) If product, services, or other assets are exchanged b) for non-monetary assets that are not readily convertible into cash, revenues or gains or losses may be recognised on the basis that they have been earned and the transaction is completed if the fair values can be determined within reasonable limits If collectability of assets received is doubtful, revenues and gains may be recognised on the basis of cash received Revenue recognition – US GAAP • FASB recognition criteria: Generally, the ‘Full Accrual’ Method is required Type of Revenue Recognition Criteria Sale of products Date of delivery Services Performed and billable Use of assets Passage of time or usage Asset disposal Date of sale AND WHAT WENT WRONG ... 3 2/6/2008 Primary issue: Timing and Measurement of Revenue • Recently, revenue recognition has been one of the most likely source of disagreement between issuers and the SEC • Revenue recognition related restatements account for 20% of the 1390 restatement announcements identified from July 2002 – September 2005. Restatements Increasing Revenue Recognition Important 4 2/6/2008 Economic Consequences – 90 Day Economic Consequences – contd. But…Subtle Changes since 2002 5 2/6/2008 Microstrategy - Software What went wrong? • The basic principles for revenue recognition are unambiguous and straightforward • Recent problems due to: • • • • Increasingly complex business practices Shift from manufacturing to a service economy Compensation packages being linked to share price and earnings In some instances, auditors have capitulated to clients to facilitate earnings management BBQ Example • Shipped barbecue grills to retailers during the fall and winter of 1996–97 • Allowed to defer payment until they had sold the grills. • Allowed to return any unsold goods. • Picked up the tab for the warehouses where the grills were stored for the winter 6 2/6/2008 Substantive similarity to Consignment • Buyer has lengthy return right • Payment is substantially contingent on resale of the product • Seller is required to repurchase the product at • a specified price; and Buyer does not assume risks of ownership due to future product pricing concessions Trade Loading • Bristol Myers Squibb – many of the products • • consumed at a constant rate (e.g. blood thinner) Sales growth a key indicator of future performance Sales incentives at end of quarter to encourage wholesalers to accept more product BMS – Sales Growth 7 2/6/2008 Widespread concern with … • revenue is reported in the incorrect period • (“cutoff” errors) revenue is recognised although never actually earned The Four Criteria THE SEC GUIDANCE SAB 104 Overview • Why Do We Need SAB 104? • • • FASB has never issued a specific standard on revenue recognition Many cases of inappropriate recognition have led to enforcement cases SAB 104 does not depart from FASB requirements, but provides guidance in specific cases 8 2/6/2008 SAB 104 Overview • SAB 104 and Non-Public Companies • • • SEC rules and guidance are established for public companies To the extent that SEC rules provide insights into standards found in the GAAP hierarchy, they should always be followed If no other source material in the GAAP hierarchy exists, SEC pronouncements are considered authoritative for all reporting entities SAB 104 Overview • Revenue generally is realized or realizable and earned when all of the following criteria are met: • Persuasive evidence of an arrangement exists • Delivery has occurred or services have been rendered • The seller's price to the buyer is fixed or determinable • Collectibility is reasonably assured SAB 104 Overview • Revenue is NOT recognized if • Title and risks and rewards of ownership have not transferred • Revenue is contingent on meeting performance factors that have not been realized • • An enforceable claim does not exist • Individual elements of a multiple element arrangement do not satisfy certain criteria Activity does not constitute a “separate earnings process” 9 2/6/2008 GOING FORWARD Going Forward • FASB Project • Replace Earnings Process Model with Asset/Liability Model • e.g. Revenue is an increase in a contract asset or a decrease in a contract liability (or a combination of the two) that results from providing goods and services to a customer. • Aiming to issue Preliminary Views Q2 08 10