2020 BKD Telecommunications Accounting Seminar
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To Receive CPE Credit › Individuals • Participate in entire webinar • Answer polls when they are provided › Groups • Group leader is the person who registered & logged on to the webinar • Answer polls when they are provided • Complete group attendance form • Group leader sign bottom of form • Submit group attendance form to training@bkd.com within 24 hours of webinar › If all eligibility requirements are met, each participant will be emailed their CPE certificate within 15 business days of webinar
Presenters Jessica Richter, CPA, CITP, CISA® Partner jrichter@bkd.com Eric Babler, CPA Director ebabler@bkd.com
Our Goals for Today Refresh our understanding of ASC 606 Understand the effects on various telecoms that have implemented ASC 606 Learn what the potential future effects on operations may be for telecoms
ASC 606 Refresher
Creating a One-Stop Shop for Revenue Literature Current Guidance New Principle Real Estate – General – Revenue Recognition General Recognition Construction- & Production-Type Contracts Concepts Real Estate – Retail Land – Revenue Real Estate Sales (Subtopic 360-20) Contractors – Construction Revenue Recognition (Subtopic 976-605) Industry-Specific Guidance Software (Subtopic 985-605) Persuasive evidence of The transfer of a an arrangement exists promised good or (Subtopic 910-605) (Subtopic 970-605) (Subtopic 605-35) service determines when Recognition Delivery has occurred or revenue is recognized & services have been occurs when (or as) the rendered customer obtains control of the asset. Transfer can be made either at a Price is fixed or determinable point in time or over time Collectibility is reasonably assured
Scope › Contracts with customers, except • Lease contracts • Insurance contracts • Financial instruments • Certain guarantees (other than product warranties) • Certain nonmonetary exchanges
The Five-Step Model • Identify contract(s) with customer Step 1 • Identify performance obligations Step 2 • Determine transaction price Step 3 • Allocate transaction price to performance Step 4 obligations • Recognize revenue when (or as) performance Step 5 obligation is satisfied
Step 1 – Identify Contract(s) with Customer › Contract = “agreement between two or more parties that creates enforceable rights & obligations” & meets the following criteria • Commercial substance • Approval & commitment by all parties • Identifiable rights, obligations, & payment terms • Collectibility threshold Step 1: Step 2: Step 3: Step 4: Step 5: Identify Identify Determine Allocate Recognize Contract(s) Performance Transaction Transaction Revenue with Customer Obligations Price Price
Step 2 – Identify Performance Obligations › Performance obligation • Promise to transfer goods/services to customer • Can be explicitly identified in contract or implied by customary business practices • One contract could equal one or many performance obligations • Significant judgment may be required Step 1: Step 2: Step 3: Step 4: Step 5: Identify Identify Determine Allocate Recognize Contract(s) Performance Transaction Transaction Revenue with Customer Obligations Price Price
Step 3 – Determine Transaction Price › Transaction price = amount of consideration entity expects to be entitled to (after collectibility threshold is met) • Variable consideration • Revenue constraint • Significant financing component • Noncash consideration • Consideration payable to a customer Step 1: Step 2: Step 3: Step 4: Identify Step 5: Identify Determine Allocate Contract(s) Recognize Performance Transaction Transaction with Customer Revenue Obligations Price Price
Step 4 – Allocate Transaction Price to Separate Performance Obligations › Allocate based on relative standalone selling prices of separate performance obligations • Observable price when sold separately (best evidence); otherwise, estimate based on o Adjusted market assessment o Cost plus margin o Residual value – only if highly variable or uncertain Step 1: Step 2: Step 3: Step 4: Identify Determine Allocate Step 5: Identify Contract(s) Transaction Transaction Recognize Performance with Customer Price Price Revenue Obligations
Step 5 – Recognize Revenue When (or as) Performance Obligations Are Satisfied › Revenue recognized when (or as) control of good/service is transferred to customer › Transfer of control occurs when customer has ability to direct use of, & receive benefits from, good/service › Can be recognized over time or at a point in time, depending on how performance obligations are Step 1: Step 2: Step 3: Step 4: Identify Determine Step 5: Identify Allocate Contract(s) Transaction Recognize Performance Transaction with Customer Price Revenue Obligations Price
Overview of Transition Methods › Full retrospective method • Restate all prior years presented in the financials as if ASC 606 was in place › Modified retrospective method • Recognize the cumulative effect of initially applying the new revenue recognition guidance as an adjustment to the opening balance of retained earnings as of the date of adoption, e.g.,1/1/2019 • Chosen by majority of companies
Effects of Implementation
Effects of Transition on Telecoms › Overview – transition – example • Telephone and Data Systems, Inc. (TDS) ASC 606 Cumulative adjustment to retained earnings (in millions of dollars) Cumulative Cumulative Adjustment as Adjustment to a % of Retained Operating Operating Earnings Revenue Revenue TDS 164 5,109 3.21% U.S. Cellular 175 3,967 4.41% Non-Wireless Related (11) 1,142 -0.96% Amounts from annual reports http://s1.q4cdn.com/183458318/files/doc_financials/annual/2019/USM-PDF-AR-2018.pdf https://s22.q4cdn.com/412964029/files/doc_financials/annual/2018/18-41220-1_343935_client.pdf
Effects of Transition on Telecoms › Overview – transition • ILEC, CLEC, broadband (wired & wireless), video o Most impacts were related to movement of revenues between line items on the income statement • Allocation of bundle discounts o Very few had a retained earnings adjustment • No change in the timing of the revenues o Some had changes due to promotions for free installations with a contract of a certain length
Effects of Transition on Telecoms › Overview – transition • Cellular o Frequently had a retained earnings adjustment o Changed the timing of revenue & expense recognition • Primarily related to free/discounted phones with contract • Timing of recognition of commission expense o Changed line items where revenue was recognized
Significant Areas Affected › Allocation of discounts › Upfront payments made by customers › Commissions paid to employees › Directory revenue & expense
Allocation of Discounts › Requirements • If the sum of the standalone selling prices of a bundle of services exceeds the consideration, then the discount is generally allocated proportionately to all performance obligations in the contract
Allocation of Discounts › The guidance does state that if there is evidence that the entire discount relates to only one or more, but not all performance obligations, the discount is not allocated proportionately to all performance obligations in the contract • The bar is high • We have not seen many companies meet the requirements
Allocation of Discounts › Issue • Most telecoms arbitrarily recorded whole discount to internet (highest margin service) Fixed discount of $15 when taking three services – INCORRECT Standalone Selling Discount Discount Allocated Selling Price Percentage Allocation Price Local $18.00 0% $ - $ 18.00 Long distance $10.95 0% $ - $ 10.95 Internet $69.95 100% $ (15.00) $ 54.95 Video $99.95 0% $ - $ 99.95 Set-Top Box $5.95 0% $ - $ 5.95 $204.80 $ (15.00) $ 189.80
Allocation of Discounts Fixed discount of $15 when taking three services – CORRECT › Effects • Increase in internet revenue Standalone Selling Discount Discount Allocated Selling Price Percentage Allocation Price • Decrease in Local $18.00 9% $ (1.32) $ 16.68 o Video revenue o Local service revenue Long distance $10.95 5% $ (0.80) $ 10.15 o Other revenues Internet $69.95 34% $ (5.12) $ 64.83 • Re-imagining the bundle Video $99.95 49% $ (7.32) $ 92.63 • Consolidating bundles Set-Top Box $5.95 3% $ (0.44) $ 5.51 • Moving away from bundles $204.80 $ (15.00) $ 189.80
Upfront Payments Made by Customers – Activation & Installation › Issues • Many contracts include nonrefundable upfront fees that are paid at or near contract inception • Must assess whether the fee relates to the transfer of a promised good or service to the customer • Fees administrative in nature are not separate performance obligations • Activities that improve the telecom’s network do not transfer a good or service to the customer
Upfront Payments Made by Customers – Activation & Installation › Effects • Installation fee may need to be recognized over time o Deferred revenue recognized over the life of the contract • Most companies have determined these charges to be administrative in nature • May include a truck roll, but most times de minimis to the customer • For most companies, this revenue is not material to the financial statements
Upfront Payments Made by Customers – Installation Fees Waived Annual Internet Service Revenue Customer Contract Term Monthly Fee Total Days 12/31/2020 12/31/2021 12/31/2022 12/31/2023 Total Customer A 6/1/2020 6/1/2023 $ 69.95 1,095 $ 489.65 $ 839.40 $ 839.40 $ 839.40 $ 3,007.85 Customer B 3/1/2020 3/1/2023 $ 69.95 1,095 $ 699.50 $ 839.40 $ 839.40 $ 839.40 $ 3,217.70 Customer C 2/1/2020 2/1/2023 $ 69.95 1,096 $ 769.45 $ 839.40 $ 839.40 $ 839.40 $ 3,287.65 Customer D 1/1/2020 1/1/2023 $ 69.95 1,096 $ 839.40 $ 839.40 $ 839.40 $ 839.40 $ 3,357.60 Customer E 4/1/2020 4/1/2023 $ 69.95 1,095 $ 629.55 $ 839.40 $ 839.40 $ 839.40 $ 3,147.75 Customer F 5/1/2020 5/1/2023 $ 69.95 1,095 $ 489.65 $ 839.40 $ 839.40 $ 839.40 $ 3,007.85 Customer G 8/1/2020 8/1/2023 $ 69.95 1,095 $ 349.75 $ 839.40 $ 839.40 $ 839.40 $ 2,867.95 Customer H 9/1/2020 9/1/2023 $ 69.95 1,095 $ 279.80 $ 839.40 $ 839.40 $ 839.40 $ 2,798.00 $ 559.60 $ 4,546.75 $ 6,715.20 $ 6,715.20 $ 6,715.20 $ 24,692.35
Upfront Payments Made by Customers – Installation Fees Waived Install Discount Customer Contract Term Install Fee Total Days 12/31/2020 12/31/2021 12/31/2022 12/31/2023 Total Customer A 6/1/2020 6/1/2023 $ (150.00) 1,095 $ (29.18) $ (50.00) $ (50.00) $ (20.82) $ (150.00) Customer B 3/1/2020 3/1/2023 $ (150.00) 1,095 $ (41.78) $ (50.00) $ (50.00) $ (8.22) $ (150.00) Customer C 2/1/2020 2/1/2023 $ (150.00) 1,096 $ (45.71) $ (49.95) $ (49.95) $ (4.38) $ (150.00) Customer D 1/1/2020 1/1/2023 $ (150.00) 1,096 $ (49.95) $ (49.95) $ (49.95) $ (0.14) $ (150.00) Customer E 4/1/2020 4/1/2023 $ (150.00) 1,095 $ (37.53) $ (50.00) $ (50.00) $ (12.47) $ (150.00) Customer F 5/1/2020 5/1/2023 $ (150.00) 1,095 $ (33.42) $ (50.00) $ (50.00) $ (16.58) $ (150.00) Customer G 8/1/2020 8/1/2023 $ (150.00) 1,095 $ (20.82) $ (50.00) $ (50.00) $ (29.18) $ (150.00) Customer H 9/1/2020 9/1/2023 $ (150.00) 1,095 $ (16.58) $ (50.00) $ (50.00) $ (33.42) $ (150.00) $ (1,200.00) $ (274.98) $ (399.91) $ (399.91) $ (125.20) $ (1,200.00)
Upfront Payments Made by Customers – Installation Fees Waived Revised Annual Revenue Customer Contract Term Monthly Fee Total Days 12/31/2020 12/31/2021 12/31/2022 12/31/2023 Total Customer A 6/1/2020 6/1/2023 $ 69.95 1,095 $ 460.47 $ 789.40 $ 789.40 $ 818.58 $ 2,857.85 Customer B 3/1/2020 3/1/2023 $ 69.95 1,095 $ 657.72 $ 789.40 $ 789.40 $ 831.18 $ 3,067.70 Customer C 2/1/2020 2/1/2023 $ 69.95 1,096 $ 723.74 $ 789.45 $ 789.45 $ 835.02 $ 3,137.65 Customer D 1/1/2020 1/1/2023 $ 69.95 1,096 $ 789.45 $ 789.45 $ 789.45 $ 839.26 $ 3,207.60 Customer E 4/1/2020 4/1/2023 $ 69.95 1,095 $ 592.02 $ 789.40 $ 789.40 $ 826.93 $ 2,997.75 Customer F 5/1/2020 5/1/2023 $ 69.95 1,095 $ 456.23 $ 789.40 $ 789.40 $ 822.82 $ 2,857.85 Customer G 8/1/2020 8/1/2023 $ 69.95 1,095 $ 328.93 $ 789.40 $ 789.40 $ 810.22 $ 2,717.95 Customer H 9/1/2020 9/1/2023 $ 69.95 1,095 $ 263.22 $ 789.40 $ 789.40 $ 805.98 $ 2,648.00 $ 559.60 $ 4,271.77 $ 6,315.29 $ 6,315.29 $ 6,590.00 $ 23,492.35
Commissions Paid to Employees › Issues • Companies may pay a commission to personnel for new customer sign- ups. • Sales commission meet the criteria for recognition as an asset as a cost to obtain a contract which is then recognized as expense over the life of the contract with the customer. o Contract may not have a specific life & you will have to determine average life of the customer
Commissions Paid to Employees › Effects • Few companies pay employees commissions, mostly larger ones • Amortize expense over contract term or customer life • Expenses are spread out over the contract life rather than being recognized all upfront when paid
Commissions Paid to Employees Expense Employee Contract Term Commission Total Days 12/31/2020 12/31/2021 12/31/2022 12/31/2023 12/31/2024 12/31/2025 12/31/2026 Total Employee A 6/1/2020 6/1/2025 $ 5,000.00 1,826 $ 583.24 $ 999.45 $ 999.45 $ 999.45 $ 999.45 $ 418.95 $ - $ 5,000.00 Employee B 3/1/2020 3/1/2026 $ 2,500.00 2,191 $ 348.01 $ 416.48 $ 416.48 $ 416.48 $ 416.48 $ 416.48 $ 69.60 $ 2,500.00 Employee C 2/1/2020 2/1/2023 $ 3,000.00 1,096 $ 914.23 $ 999.09 $ 999.09 $ 87.59 $ - $ - $ - $ 3,000.00 Employee A 1/1/2020 1/1/2024 $ 1,500.00 1,461 $ 374.74 $ 374.74 $ 374.74 $ 375.77 $ - $ - $ - $ 1,500.00 Employee B 4/1/2020 4/1/2024 $ 4,000.00 1,461 $ 750.17 $ 999.32 $ 999.32 $ 999.32 $ 251.88 $ - $ - $ 4,000.00 Employee C 5/1/2020 5/1/2026 $ 3,500.00 2,191 $ 389.78 $ 583.07 $ 583.07 $ 583.07 $ 583.07 $ 583.07 $ 194.89 $ 3,500.00 Employee A 8/1/2020 8/1/2025 $ 2,000.00 1,826 $ 166.48 $ 399.78 $ 399.78 $ 399.78 $ 399.78 $ 234.39 $ - $ 2,000.00 Employee B 9/1/2020 9/1/2026 $ 1,000.00 2,191 $ 55.23 $ 166.59 $ 166.59 $ 166.59 $ 166.59 $ 166.59 $ 111.82 $ 1,000.00 $ 22,500.00 $ 3,581.89 $ 4,938.51 $ 4,938.51 $ 4,028.04 $ 2,817.25 $ 1,819.47 $ 376.31 $ 22,500.00
Amortization of Revenue & Expenses › Issue • Amortize revenue & expenses on a systematic basis, consistent with the pattern of transfer of the service o Over length of the contract o No contract, use judgment to calculate average customer term • Churn = customers who churned/beginning customers • Lifetime = one/churn › Effect • Change in timing of recognition
Amortization of Revenue & Expenses Customer Term as Reported Term as Reported Company Customer Type contracts? on 10-Q - 9/30/2018 on 10-Q - 3/31/2019 Mediacom Residential No 36 months 36 months Business Yes 1 to 10 years 1 to 10 years CenturyLink Residential Yes 30 months 30 months Business Yes 1 to 5 years 1 to 5 years TDS Residential Not Reported Not Reported 14 to 60 months Business Not Reported Not Reported 14 to 60 months Frontier Residential Not Reported 3.8 years 3.8 years Business Not Reported 3.8 years 3.8 years Charter Residential No 6 months 6 months Small Business No 6 months 6 months Enterprise Yes 2 to 7 years 2 to 7 years Information from September 30, 2018 10-Q as reported on https://www.sec.gov/edgar/searchedgar/companysearch.html Information from March 31, 2019 10-Q as reported on https://www.sec.gov/edgar/searchedgar/companysearch.html
Directory Revenue & Expense › Issue • Companies should record revenue & expense when physical directory is published • Change from current practice • Digital or online directory o No change from current practice
Directory Revenue & Expense › Effect • Revenue & expense recorded in month of publication • Monthly & quarterly reporting obligations requiring GAAP financials are impacted • For most companies, revenue & expenses not material to the financial statements
Future Considerations
Future Considerations › Recent effective date update › Collaborative effort › Ongoing evaluation › Conversations with consultants
Effective Date Update › Recently issued ASU 2020-05 postponed effective dates as follows • The delay is only effective if the entities have not yet issued or made available for issuance their financial statements
Effective Date Update › Delay does NOT impact ASU 2018-08, Not-for-Profit Entities: Clarifying the Scope and the Accounting for Contributions Received and Contributions Made › Delay of ASC 606 implementation is NOT required • With ASC 842, Leases coming, it might make a lot of sense to get ASC 606 done now › Early adoption is encouraged
Collaborative Effort › Management will want to work closely with accounting department to understand & champion accounting & reporting requirements › Requires collaboration across departments • Marketing to assess new service & product offerings o Discounts, bundles, other promotions • Plant to assess activation & installation charges • Human resources to assess commission pay structure
Ongoing Evaluation › Effort doesn’t stop once the standard has been adopted › Evaluation of current & future discounts/promotions offered to customers • Any change in price • Any change in discounts • Any change is service/product offerings • Any concessions o For example: free install for some customers
Ongoing Evaluation › Future changes in activation & installation charges › Changes to or addition of commissions to employees › Changes in directory revenue & expenses • Publication date change • Physical to digital directory
Conversations with Consultants › Discuss accounting changes with • External accounting firm o To understand accounting & reporting requirements o Effect on any loan covenants o Don’t let the accounting of a decision drive the decision • Cost consultants o To understand any changes in timing of revenue & expense recognition o To understand any new assets & liabilities on the balance sheet
Summary › Implementation & ongoing compliance with ASC 606 is a complex process that requires • Collaboration with multiple departments at the company • Good documentation around the five-step model • Strong communication with various stakeholders o Board o Consultants o Owners o Regulators o Lenders
Questions?
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Thank You! The information contained in these slides is presented by professionals for your information only & is not to be considered as legal advice. Applying specific information to your situation requires careful consideration of facts & circumstances. Consult your BKD advisor or legal counsel before acting on any matters covered
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