Revenue - SEC comment letter observations

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Listen to our podcast on revenue SEC comment letter observations

What has the SEC staff commented on in letters to companies on the new revenue standard? In this podcast, we examine some of the SEC comment letters related to companies who have adopted the new revenue standard and have received comment letters through October 2018. We first give a quick summary of the SEC comment letter process. Then from our review of the letters, we’ll discuss our observations, including:

  • Identification of performance obligations
  • Estimating transaction price
  • Timing of revenue recognition
  • Principal versus agent assessments (gross versus net reporting of revenue)
  • Capitalized costs related to revenue contracts 

Companies should continue to consider how they describe their business outside of the financial statements -- such as earnings releases or investor presentations -- when they draft their disaggregated revenue disclosures.

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Heather Horn

US Strategic Thought Leader, National Professional Services Group, PwC US

David Schmid

International Accounting Leader, National Professional Services Group, PwC US

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