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)
  • Meredity Canady, American Express
  • Kristin Derington-Ruiz, PricewaterhouseCoopers LLP
  • David Elizandro, BNY Mellon
  • Sydney Garmong, Crowe Horwath LLP
  • Dom Guiffrida, Ernst & Young LLP
  • Lee Keel, Wells Fargo
  • Lisa Koehl, JP Morgan Chase
  • Jennifer Liner, Capital One
  • Faye Miller, McGladrey
  • Mike Pierce, KPMG LLP
  • Robert Uhl, Deloitte LLP
  • Markus Veith, Grant Thornton LLP
  • Xihao Xu, TD Bank
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).

The Task Force has removed and/or addressed selected implementation issues included in the original plan. They have retained the original issue #s for the table below.

Issue # Description of Implementation Issue Status
1 Revenues scoped out of ASC 606
  • Lending-related fees (ASC 310-10-25-9 to 13 and ASC 310-20)
  • Interest income on receivables
  • Rebates of accrued interest income
  • Prepayment charges
  • Delinquency charges (late fees)
  • Loan commitment fees
  • Loan origination fees and costs, premiums, discounts
  • Mortgage servicing rights
Question submitted to FASB TRG
2 Revenues to be evaluated for applicability of ASC 606
  • Other bank service charges, including online, month fees, NSF, etc.
  • Bundled arrangements that include a service-based fee arrangement and an out of scope financial instrument
  • Stand-by loan guarantee fees Note: discussed in ASC 310-10-60-4 but references ASC 605, now 606

3 Determining the applicability of ASC 606 to Card Arrangements for Card Issuing Banks and Merchant Acquiring Banks, including:
  • Evaluation of interchange and merchant revenue
  • Evaluation of rewards programs and other services, specifically whether they are considered a performance obligation and if so, when the obligation is satisfied
  • Evaluation of cardholder fee revenue – determining the applicability of ASC 310 vs. 606

4 Sale of Non-Operating Assets (Other Real Estate Owned)
This implementation issue provides considerations for depository institutions in applying the guidance in ASC 606 to sales of other real estate owned.
Submitted to FinREC - July 2015
6 Investment Management Revenue Recognition Accounting Issues - See Asset Management Task Force
7 Broker Dealer Revenue Recognition Accounting Issues - See Brokers-Dealers Task Force


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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