Investment Asset Management 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:

    • Chad B. Gazzillo, KPMG LLP (Chair)
    • Mike Barkman, Ernst & Young LLP
    • Rajan Chari, Deloitte & Touche LLP
    • David Elizandro, BNY Mellon
    • Timothy J. Lorber, Legg Mason & Co., LLC
    • Christopher May, PricewaterhouseCoopers LLP
    • James McDonald, BlackRock, Inc
    • Lindsey Oshita, Franklin Resources, Inc.
    • John Stomper, Grant Thornton LLP
    • Tracy Whetstone, McGladrey LLP
    Staff Contact: Irina Portnoy,


    Below is a list of potential revenue recognition implementation issues identified by the Asset Management and Investment Companies Revenue Recognition Task Force. The list will be updated as the task force continues its 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 Status
    1 Who is the customer?
    This implementation issue will discuss considerations needed when assessing whether a contract exists between an asset manager and customer, and identifying who the customer is (the investor or the fund)?
    Submitted to FinREC
    2 Management fee revenues
    Recognition of management fee revenue. This implementation issue will discuss when and how to recognize revenue from management fees, including unitary fees, under the new model.
    Submitted to FinREC
    3 Fee waivers / Fund Expense Reimbursements
    Accounting for management fee waivers and customer expense reimbursements. This implementation issue will discuss how to account for management fee waivers and customer expense reimbursements in asset management contracts.
    Submitted to FinREC
    4 Costs to fulfill and costs to obtain a contract, including launch costs, ongoing servicing expense, and sales bonus expense
    5 Incentive or performance fee revenues (including carried interest)
    This implementation issue discusses how and when incentive or performance revenue, excluding carried interest, should be recognized under the new standard.
    Submitted to AICPA RRWG
    Incentive-based capital allocations
    This implementation issue raises the question of whether incentive-based capital allocations, such as carried interest, fall within the scope of FASB ASC Topic 606 or FASB ASC Topic 323, Investments—Equity Method and Joint Ventures.
    Submitted to AICPA RRWG
    6 Recognition of contingent deferred sales charges
    This implementation issue evaluates the criteria used to recognize revenue from CDSC under the new guidance, including the identification of separate performance obligations and variable consideration.
    Submitted to AICPA RRWG
    7 Deferred distribution commission expenses (back end load funds)
    How an asset manager (or its mutual fund distributor subsidiary) should account for commissions paid to a mutual fund distributor for back-end load funds. This implementation issue will discuss considerations for applying the guidance in FASB ASC 340 to deferred distribution commission expenses.
    Submitted to FinREC
    8 Broker-Dealer Revenue Recognition issues (provide feedback and consider industry specifics, as needed)


    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 Investment Companies Revenue Recognition Task Force and the Investment Companies Expert Panel recommend the following AICPA products for current revenue recognition issues:

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