Depository and Lending Institutions Revenue Recognition Task Force 

    AICPA Revenue Recognition Task Forces are charged with developing revenue recognition implementation issues that will provide helpful hints and illustrative examples for how to apply the new Revenue Recognition Standard.

    Task Force Members:

    • Paul Bridge, BDO (Chair)
    • Sydney Garmong, Crowe Horwath LLP
    • Dom Guiffrida, Ernst & Young LLP
    • Todd Sprang, Clifton Larsen Allen
    • Markus Veith, Grant Thornton LLP
    • Mike Lundberg, McGladrey LLP
    • Kristin Derington-Ruiz, PricewaterhouseCoopers LLP
    • Mike Pierce, KPMG LLP
    • Xihao Xu, TD Bank
    • David Elizandro, BNY Mellon
    • Meredity Canady, American Express
    Staff Contact: Salome J Tinker,


    Below is a list of potential revenue recognition implementation issues identified by the Depository and Lending Institutions Revenue Recognition Task Force. The list will be updated as the task force continues it discussions. Full revenue recognition implementation issues will be posted below for informal comments after review by the AICPA Financial Reporting Executive Committee (FinREC).

    Issue # Description of Implementation Issue
    1 Points paid for interest rate lock commitments
    2 General bank service charges, including online, month fees, NSF, etc.
    3 Recognition of loan origination fees
    4 Mortgage servicing rights
    5 Mortgage interest, fixed and variable rate (scoped out, but want to specifically acknowledge it)
    6 Fees that are not scoped out under existing guidance
    7 Bundles that include a service-based fee arrangement and a financial instrument (e.g, a discount or waiver of a depository account service charge if the customer has a credit card or loan outstanding or some other similar arrangement
    8 Trustee or custodian fees
    9 Recognition of performance fees (including carried interest)
    10 Recognition of up-front distribution fees (initial servicing a separate performance obligation or a combined performance obligation with overall management responsibility?)
    11 Identifying the contract (who is counterparty to the asset manager in the arrangement, the fund or the investor? – appears to be geographic differences in views)
    12 Accounting for up-front distribution commission expenses (cost to obtain contract vs. cost to fulfill contract)
    13 Launch costs (cost to obtain contract vs. cost to fulfill contract)
    14 Management fee revenues
    15 Performance fee revenues (including carried interest)
    16 Fee waivers / Fund Expense Reimbursements
    17 Contingent deferred sales charge revenue ("CDSC")
    18 Up front distribution fee revenue (i.e., sales commission)
    19 Up front distribution commission expenses (front end load funds)
    20 Ongoing distribution fee revenues or back end commissions fee revenue (e.g., 12b-1 fees)
    21 Launch costs
    22 Ongoing distribution expense (e.g., trailers paid to 3rd party distributors)
    23 Deferred distribution commission expenses (back end load funds)
    24  Ongoing servicing expense
    25 Sales bonus expense
    26 Application of the new guidance to credit card reward or customer loyalty programs including the determination of whether fulfilling the program represents a separate performance obligation
    27 Interaction of standard with FAS 91 language (credit card fees)
    28 Services that credit card provides (concierge, lounge access) pattern of obligation
    29 The underlying principles of ASC 360-20 provide that full profit on a real estate sale could be recognized if the profit was determinable and the earnings process was virtually complete


    Draft Revenue Recognition Implementation Issues included for informal comment, when available, will be listed below.

    Respondents should submit any comments including the implementation issue number to by the dates noted below:

    Issue # Comment Due Date

    The Depository and Lending Institutions Revenue Recognition Task Force and the Depository and Lending Institutions Expert Panel recommend the following AICPA products for current revenue recognition issues:

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