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Financial Reporting and Regulatory Update

Third Quarter 2017

From the AICPA

Revenue Recognition Task Force Exposure Drafts

Based on work of the 16 AICPA industry task forces for revenue recognition, the AICPA’s Financial Reporting Executive Committee (FinREC) has issued working drafts of revenue recognition accounting issues that include proposed content for the new AICPA “Accounting Guide on Revenue Recognition” that addresses ASU 2014-09, “Revenue From Contracts With Customers.” Some of the working drafts have gone through the approval process and have been finalized for the guide, and others are in earlier phases.

Recently, working drafts have been posted for comment for the following industries, and for these, comments are due either Nov. 1, 2017, or Dec. 1, 2017, as indicated on each industry task force webpage:

The status of issues addressed by other industry task forces can be found on the AICPA’s Revenue Recognition page.


Broker-dealers may find more in-depth analysis on the working draft for their industry in “Soft-Dollar Arrangements: What FinREC’s Recent Draft Implementation Paper Means for Revenue Recognition,” issued by Crowe on Sept. 15, 2017.

Auditor Involvement With Exempt Offerings

In July, the Auditing Standards Board of the AICPA issued Statement on Auditing Standards (SAS) 133, “Auditor Involvement With Exempt Offering Documents.” The audit standard addresses the auditor’s responsibilities in situations where the auditor is involved with offerings exempt from registration with the SEC. Such offerings would include private placements such as those under SEC Regulation A, “Conditional Small Issues Exemption,” or Regulation D, “Limited Offer and Sale of Securities Without Registration Under the 1933 Act.”

Auditor involvement, under SAS 133, includes situations where the auditor’s report on financial statements or review report on interim financial information is included or incorporated by reference into an exempt offering document, and the auditor performs activities related to the offering document, such as reading it. When the auditor is involved with an exempt offering, the new audit standard requires that the auditor performs specific procedures, including subsequent event procedures that are designed to identify events occurring between the date of the auditor’s report and the distribution of the exempt offering document.

The audit standard is effective for exempt offering documents that are initially distributed, circulated, or submitted on or after June 15, 2018.