At yesterday's Financial Accounting Standards Advisory Council (FASAC) meeting, the SEC staff clarified its views on how registrants would reflect their implementation of ASC 606¹ (the “new revenue standard”) in the five-year table required under SEC Regulation S-K, Item 301.² The staff indicated that it would not object if a registrant reflected its adoption of the new revenue standard in the five-year table on a basis that is consistent with the adoption in its financial statements (i.e., reflected in less than each of the five years in the table). In other words, in a manner consistent with the new revenue standard, a registrant could present in the five-year table (1) only the most recent three years if the registrant uses the full retrospective method to adopt the new revenue standard or (2) only the most recent fiscal year if it uses the modified transition basis. Regardless of the transition method adopted, registrants would be expected to disclose the method they used to reflect the information (e.g., how the periods are affected) and that the periods are not comparable.

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1 FASB Accounting Standards Codification Topic 606, Revenue From Contracts With Customers.

2 SEC Regulation S-K, Item 301, “Selected Financial Data.”