Comments on proposed deferral of effective dates

The firm submitted comments on the FASB’s proposed Accounting Standards Update, Effective Dates for Certain Entities, to defer the effective dates of certain guidance for select entities. In general, the firm agrees with deferring the effective date of ASC 606, Revenue from Contracts with Customers, for franchisors that are not public entities and have not yet issued financial statements. The firm also agrees with deferring the effective date of ASC 842, Leases, for all nonpublic companies, and for NFPs that have conduit debt and have not yet issued financial statements reflecting the adoption of the new standard. However, the firm notes that some NFPs with conduit debt report varying degrees of financial information through municipal bond systems, and we recommend that the FASB consider clarifying whether this financial information counts as issued financial statements for the purposes of applying the deferral.

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