Yesterday the SEC’s Division of Enforcement sought voluntary production of documents from Green Mountain Coffee Roasters, the maker of the single-cup Keurig brewers. At issue is Green Mountain’s revenue recognition policy. Green Mountain is a publicly traded company with a market capitalization of $4 billion and is audited by PWC, so it most likely has a revenue recognition policy in place.
Smaller companies, particularly privately-held companies, probably don’t have a written revenue recognition policy, but they should. Revenue recognition is always a hot-topic with the SEC and it should be hot topic with any business owner. Revenue recognition under generally accepted accounting principles in the United States is a complex area where even seemly simple transactions can open some very complicated recognition rules.
Companies should maintain a written revenue recognition policy for each of their products or groups of products (if they are homogeneous). Having a well written policy is the first step in ensuring that revenue is recognized in a consistent manner on a company’s financial statements. When I’ve written revenue recognition policies in the past, I’ve generally followed this outline:
- Describe the product or group of products
- How and where the product will be sold.
- How and when the earnings process is complete.
- References to any accounting literature
- The journal entry to record the revenue and/or deferral of revenue and supporting accretion schedules.
Because each product or transaction is so unique, it’s very difficult to devise a standard “check-the-box” approach to determining revenue recognition and it’s probably ill-advised. Many companies have well-trained and talented accounting staff that can go through all the complex revenue recognition rules to write up a policy. In the event that they don’t have the expertise or resources (mainly time), hiring a certified public accountant to perform a SAS 50 engagement (reports on the application of accounting principles) is also an option.
Note: SAS 50 was later amended by SAS 97, Amendment to Statement of Auditing Standards No. 50, Reports on the Application of Accounting Principles. It’s also known by the less sexier name AU Section 625.
