Bridging the "New GAAP" in the Upcoming 10-K

[...]senior OCA staff members have emphasized the perils to effective ICFR stemming from serial adoption of each of the New GAAP standards according to its future effective date, with the company potentially running out of time to achieve full and timely compliance with all such standards.[ASC 606 a...

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Veröffentlicht in:Insights; the Corporate & Securities Law Advisor 2017-12, Vol.31 (12), p.3-18
Hauptverfasser: Dixon, Catherine, Odoner, Ellen, Alterbaum, Alicia
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Sprache:eng
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Zusammenfassung:[...]senior OCA staff members have emphasized the perils to effective ICFR stemming from serial adoption of each of the New GAAP standards according to its future effective date, with the company potentially running out of time to achieve full and timely compliance with all such standards.[ASC 606 and ASC 842] early, primarily to simplify the communication of our results by eliminating the need for non-GAAP revenue reporting_ [and] to provide one set of restated financial statements to investors.'23 Microsoft's Form 10-K contains an expansive financial statement footnote presentation-in both narrative and tabular format, in Note 1 to the audited financial statements filed as part of the Form 10-K- of the expected quantified effects of the company's adoption of these New GAAP standards on July 1, 2017.[...]while disclaiming any reportable material ICFR changes during its fiscal 2017 fourth quarter, Microsoft disclosed in management's annual ICFR report (in the body of the company's fiscal 2017 Form 10-K) that [d]uring fiscal year 2017, we implemented internal controls to ensure we have adequately evaluated our contracts and properly assessed the impact of the new accounting standards related to revenue recognition and leases on our financial statements to facilitate the adoption on July 1, 2017.According to this disclosure, which is substantially similar to the SAB 74 disclosure Korn Ferry later made in a Form 10-Q filed September 8, 2017 (in a footnote to the quarterly financial statements): The Audit Committee is playing an active role in overseeing the Company's implementation of the new revenue recognition standard.According to reports from attendees at an EITF meeting held on July 20, 2017, an SEC staff observer announced that the staff would not object if such private companies elect to defer adoption of the new revenue and lease accounting standards until the more distant effective dates permitted for private companies that are not PBEs.38 OCAs announcement, which has been codified by the FASB,39 comes as welcome news to registrants required to include financial statements or summarized financial information of non-consolidated investees that would not otherwise qualify as PBEs and over which, by FASB's own definition, these registrants may lack the degree of control that would be necessary to compel accelerated adoption of the new standards.
ISSN:0894-3524